Any new road project should take account of the County Bio-Diversity and Climate Change Adaption Plan.
At present this does not appear to be the case and it can result in expert findings and best practices from these reports being overlooked.
Any new road project should take account of the County Bio-Diversity and Climate Change Adaption Plan.
At present this does not appear to be the case and it can result in expert findings and best practices from these reports being overlooked.
Any new road project should take account of the County Heritage Plan
At present it does not appear to be a condition or a recommendation and this can result in expert findings and best practices being overlooked.
Extension of the existing development boundary.
We believe there are a number of advantages to extending the boundary.
1. Infrastructure already in place
2. Enhancement of village and the area
3. Provide Eco Quality housing for locals that can't meet local needs in the area.
GSI pleased to note the use of map data in the associated Strategic Envirionmental Assessment (SEA) report. However recommend that as data sets are regularly updated that the most recent data be used in the County Development PLan.
Land Registry Folios for site in question
Please find attached a submission on the Westmeath CDP
ORS were engaged by Lynx Developments Limited to make a submission on the Draft Westmeath
County Development Plan 2021-2027. The subject lands which are contained within folio
WH24160F are well serviced for foul, surface water and water, primarily because construction
works commenced on this site in 2007. Also, considering that adequate infrastructure services exist
in this area, we would submit that the 3.82 hectares of this folio are extended to a residential zoning
objective as proposed by the Draft Westmeath County Development Plan 2021-2027 to support
the sustainable growth of this designated self-sustaining town.
The Executive Committee of the Combined Counties Football League would like to make this formal submission requesting re-zoning of 4.98 hectares listed in Folio No. WH5957 from its current zoning mixed status of residential (expired)/Industrial to be re-zoned as Sporting Recreational in order to develop and complete the CCFL Centre of Excellence as outlined below and as per attached plan.
Who will use this new Centre of Excellence:
All facets of the football family in the region along with members of the local community will have access to the proposed facility. CCFL representative teams and clubs from the league along with the local football team will be the primary beneficiaries of the new facility. CCFL representative teams and CCFL clubs encompass Under 17,18,19 players along with adult men and women’s teams. Local football team will be catering for schoolboy and schoolgirl teams at Under 8, Under 10, Under 12, Under 14, Under 16, Under 17 age categories. In addition, the facility will contain a proposed community walkway complete with lighting (900 mitre distance) open for use for all members of the community.
What will the Centre of Excellence consist of:
Phase 1 (complete).
Purchase of site and completion of topographical study
Phase 2
Review current zoning and complete re-zoning application through Westmeath Co. Co.
Phase 3
Completion of Feasibility study.
Phase 4
Completion of planning application
Phase 5
Erect perimeter boundary around pitches and build walkway
Development of 3 pitches;
Install drainage infrastructure for entire site.
Install ducting, draw chambers and floodlight bases for pitches 1 & 2.
Acquisition of mower for ongoing and essential maintenance.
Building of equipment storage shed.
Phase 6
Erect floodlighting on pitch 1 (to a minimum of 300lux)
Building of complex including;
Phase 7
Replace pitch 2 with FIFA approved all-weather pitch.
Erect floodlighting on pitch 2 to a minimum of 300lux (new all-weather pitch).
Costs and Funding:
The total cost of this entire project is estimated at €1.1 million. This excludes the purchase of the site which is currently in the ownership of CCFL Park Limited. Phases 1 to 5 are estimated at €250,000. Phase 6 is estimated to cost €400,000 and Phase 7, the final phase of the project planned for 2024 to cost €450,000. Funding for the project will be attained through existing and future league revenues, Sports Capital Regional funding, FAI grants, facility naming rights, local partnership arrangements for sharing of facility and future hire of the facility to all sporting bodies (local and national). The league also intends to complete various fund-raising activities to enhance capital expenditure requirements.
Why the Development:
The Combined Counties Football League was founded in 2005 encompassing clubs from across the Laois, Offaly, Westmeath and Longford.
Our Mission: Is to provide Football for all our Teams, in a manner which will improve, develop, and enhance the standards of our game, in the playing, administration and refereeing of football in line with L.F.A. and F.A.I. objectives
From the onset of the league it was always the ambition of the leagues Executive Committee, in conjunctions with its membership, to establish a centre of excellence and a home for the league. The development would allow for the staging of league representative games, the playing of various league cup finals and semi-finals, the preparation of CCFL representative squads, and through hiring of the facility the centre would present the league with an opportunity to raise revenue for the development and up-keep of the facility. The costs to date have been met by the league through prudent management of league finances accumulated from affiliations and sponsorship over many years.
The proposed sharing of the development with the community enhances the project. The league would propose through the sharing of the facility to maximise its use under a pitch sharing arrangement with the local football team while providing a fantastic amenity to the local community through the provision of the walkway.
This Vision for Community Wellbeing identifies the key issues that member groups in Westmeath PPN consider are important for their community to be “The best that it can be for this and future generations”
Overarching Vision for Westmeath Community Wellbeing
“Westmeath is a flourishing community with a thriving economy where we live and work sustainably. It is a welcoming and safe place which values and respects all people. We enjoy a beautiful and healthy natural environment and celebrate our rich heritage. Each of us has the freedom to live the life we choose and have a say in decisions that affect us. We all participate in our communities making them vibrant places where no-one is left behind. We are all supported to be the best that we can be.’’
OPW Comments attached
Westmeath Public Participation Network (WPPN) is an independent network of Community and Voluntary Organisations across County Westmeath. WPPN currently represents over 740 community groups across 3 pillars of:
This WPPN submission is in relation to Broadband (or the lack of it) in Westmeath, particularly in Rural Areas. This lack of broadband has been especially highlighted during this Covid-19 Pandemic.
Today, modern technology dominates our communication. With a massive range of ways in which we can stay connected, but most of these channels of communication required broadband.
It is well known that communication is key to building and maintaining relationships, knowledge, information and advancement. Modern forms of communication allow us to stay in touch with friends, family, essential services, work colleagues and organisation from anywhere in the world. However, without access to broadband many of the citizens of Westmeath are being very disadvantaged. Many people of all ages are really struggling, feeling isolated and cut off because of lack of adequate broadband access. One thing that this pandemic is showing is that broadband is no longer a luxury, access to broadband is really a prerequisite for modern living.
While communications have gone on line with Zoom, Facetime, etc; yet without broadband:
Poor broadband connectivity impedes the ability of individuals and communities to thrive in the digital economy. In addition to the effects on educational outcomes, lack of fast Internet access and cell phone only access are associated with disadvantages that have lifelong consequences.
Westmeath needs to look at ways of improving broadband for those who simply cannot get broad band in their areas. It is no longer good enough to say that broadband will be in your area in 3 to 5 years’ time. Like the roll out of rural electrification, every home is deserving of efficient, affordable high-speed broadband; this is not a luxury it is a necessity of modern Ireland; no one should be left behind or disadvantaged due to where they live.
How Do the Council stand by this ?
T0 propose the rezoning of land at Marlinstown, Mullingar Co Westmeath. The subject site is currently unzoned land having previously been zoned under Enterprise and Employment & Institutional and Educational in the local area plan for 2008-2014, The Mullingar Local Area Plan 2008-2014.Please see attached cover letter and report.
Please refer to the attached document submitted on 21/05/2020.
We present herein the importance and significance of the subject lands and the proposals as merit consideration in respect of key Departmental Guidelines namely, Rebuilding Ireland, the National Planning Framework and crucially and more recently Housing Options for Our Ageing Population (February 2019).
This submission is made specifically in relation to the application of the Open Space land use zoning designation to lands located to the rear of Gainevale House, Mullingar Road, Multyfarnham, Co. Westmeath as presented within the Draft Westmeath County Development Plan 2021-2027. The location and extent of the subject lands, which are in the ownership of Ailish Loughrey and her family, is as identified within the detailed submission attached.
The purpose of this submission is to seek the alteration of the land use zoning designation which applies to the identified lands from Open Space as indicated within the Draft Westmeath County Development Plan 2021-2027 to Existing Residential.
We consider that applying the Existing Residential land use zoning designation to the subject lands more accurately reflects the current use of the lands would be more consistent with the proper planning and sustainable development of Multyfarnham, having regard to the local character of the village and its surroundings.
The current (and proposed) zoning unfairly and prejudicially restricts the property rights of the existing residential occupier to provide ‘public’ open space for the wider community.
The Subject land to be included in the Development Boundary of Milltownpass and to be zoned for Proposed Residential Land Use Zoning, having regard to the local character of the village, the location of the land, the surrounding area and that part of the land as currently zoned as Established Residential.
The Subject land to be included in the Development Boundary of Rochfortbridge and to be zoned for Proposed Residential Land Use Zoning, having regard to the local character of the village, the location of the land and the surrounding area.
In short, the landowner requests that the Planning Authority review the Development Plan objectives for the environs of Kinnegad, with a view to preparing a zoning plan for the area (either standalone or joint plan), to harness the significant latent capacity of the area to act as an urban extension to the existing town.
Recent planning applications have been made on the subject lands and in the surrounding area which have been granted planning permission. Development is occurring in Loughnavalley,specifically on the western side of the settlement centre. Reducing the Loughnavalley Rural Node
boundary on the western side and maintaining it on the eastern side will prejudice the ability of the Rural Node to achieve its designated functions of supporting the consolidation of the settlement and providing a viable alternative to rural one-off housing.
Attached are the observations of the National Parks and Wildlife Service.
This submission seeks the appropriate extension of the Glasson development boundary as designated in the Draft Westmeath County Development Plan 2021-2027 and the rezoning of the subject sites to provide for future residential development.
Whilst we welcome your Authority’s intentions to make amendments to the zoning plan within the framework of the current Drafting of the 2021-2027 Development Plan, the zoning should be accordingly extended to provide much more beneficial value not only to the benefit of the ability of the landowner to extend residential development opportunities but which also benefit interests of the common good such as the ability to consolidate development within and to the rear of the tight village core.
Mr Stephan Groarke wishes to make a submission on the Draft Westmeath County Development Plan 2021-2027 in relation to his lands at Ballykeeran, Athlone, Co Westmeath.
It is considered that the zoning of the subject lands to commercial offers the potential for a considered and attractive gateway to Athlone from the N55 approach.
Submission attached
There is currently no specific provision within the County Development Plan for supported/unsupported accommodation to allow the over 55 / 65 and active retired demographic to live independently.
We wish to submit that there is scope for this type of residential accommodation/dwelling to be permitted under the current ‘Community, Education & Institutional’ Zoning objective which covers a portion of the subject site. We also respectfully submit and seek endorsement that the zoning as intended to be extended over the remainder of the site as ‘Mixed Use’ will allow for this type of accommodation to be listed as permissible in the zoning matrix and that it will not prejudice same.
It is concluded that by providing an area for this type of accommodation within the village of Ballymore, this will allow older people an option to downsize to more suitable accommodation, while still living in their local community and interacting with their local community. There are of course significant opportunities presented by those who may be ageing in areas of rural isolation and who can more fully engage within the local community and support and grow existing community infrastructure currently available within the village of Ballymore. It will also allow Westmeath County Council to comply with the national policy document Housing Options for our Ageing Population – Policy Statement 2019 and simultaneously address under-utilised housing stock issues referred in the Rebuilding Ireland 2017 policy document.
As the Planning Authority will be aware, Section 15 of the Climate Action & Low Carbon Development Act 2015 and Section 10(2)(n) of the Planning & Development Act 2000 (as amended) obliges the policies and objectives of the Draft Westmeath County Development Plan (WMCDP) 2021 – 2027 to reduce greenhouse gas emissions by at least 40% by 2030, compared with 1990 levels, in line with the headline target as set out in the National Mitigation Plan 2017 and the National Transition Objective.
The objectives in the Chapter 11 which seek to reduce greenhouse gas emissions are welcome. However, in the accompanying Strategic Environmental Assessment, the Strategic Environmental Objective (SEO) in respect of ‘Climatic Factors’ seek only to ‘minimise’ emissions (p.55). This requires to be amended in accordance with national law and policy which requires a sustained and rapid reduction of emissions. This change may necessitate a fundamental review of the SEA, including in respect of the alternatives considered.
Section 9.4 of the Draft Plan make a distinction between ‘rural areas under strong urban influence’ and ‘structurally weak rural areas’ outside these catchments. It is proposed to continue to regulate housing demand by reference to specific ‘local housing need’ criteria as set out in the Sustainable Rural Housing Guidelines for Planning Authorities 2005.
Further to the Court of Justice of the European Union (CJEU) Judgement in the, so called, ‘Flemish Case’, the use of ‘bloodline’ criteria which preferences certain categories of applicant in obtaining planning permission are discriminatory and unlawful under EU law, specifically Article 43 of the EU Treaty on the freedom of movement of citizens. In 2007, the European Commission issued infringement proceedings against Ireland in respect of this matter and in 2017 the Commission revived these proceedings due to lack of progress.
We therefore recommend that Section 9.4 of the Draft Plan be removed in its entirety and replaced with a revised policy which obliges that applicants for permission in the open countryside must have genuine and demonstrated rurally-generated occupational or employment needs which specifically necessitates a ‘one-off’ dwelling in the countryside prior to being granted panning permission.
Failure to amend rural settlement policies would open up the Draft Plan to the possibility of legal challenge.
It is simply folly to have a policy which facilitates dispersed housing development against the background context of a climate and energy crisis. Such haphazard development does not support and revitalise fragile rural communities but instead hastens their decline. Such development demand should be directed first and foremost to serviced sites in rural nodes.
Section 12.17 of the Draft Plan contains some laudable policies on rehabilitating peatlands. However, Policy CPO 12.58 must be amended. In is simply unconscionable that peat extraction continue in the context of the climate and biodiversity crisis.
Article 17 of the SEA Regulations 2004 (S.I. No. 435/2004) require the Planning Authority to monitor the significant environmental effects of the implementation of the Draft WMCDP in order to identify, at an early stage, any unforeseen adverse effects and to facilitate appropriate remedial action. The SEA monitoring measures in respect of climate change include a target to: “To minimise emissions of greenhouse gasses.” (p.55). This target to minimise emissions is again contrary to national legislation which explicitly requires that emissions be reduced. It is simply not open to the Planning Authority to proceed with the current development strategy in the absence of SEO in respect of climate change that requires emissions to be reduced.
The proposed monitoring falls also short of the standard imposed by the SEA Directive. There is no reference to the results of the monitoring of the implementation of the previous development plan or to how the results of that monitoring have been taken into account during the review of the plan
Galetech Energy Services welcomes the opportunity to make this submission to Westmeath County Council in relation to the Draft Westmeath County Development Plan (CDP) 2021-2027.
The production of energy from renewable sources is one of the most important current national policy priorities. Ireland is presently subject to two mandatory EU targets to achieve 16% of total final energy consumption from renewable sources and a 20% reduction in greenhouse gas emissions by 2020. The Sustainable Energy Authority of Ireland (SEAI) published a Report[1] in April 2020 reinforcing the reality that Ireland is not on track to meet the 2020 renewable energy targets.
Moving into the next decade, Ireland will be subject to higher renewable energy targets of up to 27% and a 40% reduction in greenhouse gas emissions by 2030. In line with these commitments, the current National Renewable Energy Action Plan (NREAP) includes a 40% target for electricity generation to be achieved from renewable sources (RES-E).
Reducing the carbon intensity of electricity in Ireland is critical if we are to achieve our climate change objectives and renewable energy from onshore wind is currently the biggest generator, accounting for 85% of renewable electricity and 28% of all electricity in 2018, second only to natural gas. The Climate Action Plan to Tackle Climate Breakdown[2] 2019 has set out an ambitious 70% target for renewable energy production by 2030. This essentially requires a doubling of the currently installed onshore wind energy capacity, of 4GW, with an additional 4.2GW. Based on the Climate Action Plan assumptions, on-shore wind will provide the majority of the required electricity yield out to 2030
In energy planning terms, onshore wind energy offers the most cost-competitive and viable technology for achieving binding national targets within the relatively short timeframe to 2030. Ireland has one of the most advantageous wind resources in Europe, which can produce indigenous renewable electricity while reducing greenhouse gas emissions. Given Ireland’s binding commitments, it is absolutely imperative that every local authority contributes to national efforts and maximises the opportunities to develop its wind resources within its jurisdiction, recognising that these offer rich potential over the coming decades.
Galetech Energy Services welcomes the recognition within the Draft CDP that wind energy can make a significant contribution toward reducing greenhouse gas emissions. Furthermore, we welcome the inclusion of policies promoting the generation of renewable energy; however, we submit that all objectives and policies, particularly in relation to Policy CPO 10.132, must be fully in accordance with the Wind Energy Development Guidelines for Planning Authorities 2006 or any future revised guidelines.
The CDP has a vital role to play in establishing the land-use planning framework for renewable energy and in cascading key national energy and climate policy priorities to the local level. If Ireland is to achieve its binding commitments, it is absolutely essential that long term policy certainty is provided in order to maintain and stimulate investment in appropriately located renewable energy technologies.
[1] https://www.seai.ie/publications/2020-Renewable-Energy-in-Ireland-Report.pdf
[2] https://www.dccae.gov.ie/en-ie/climate-action/publications/Documents/16/Climate_Action_Plan_2019.pdf
Please see attached document for specific commentary.
Please see attached letter and maps.
We have reviewed the proposed decision paper and have identified a number of areas that required some further consideration and/or clarification.
Sections of Consideration or Clarification
Thank you for your time, and we hope these proposals aid in the future development of renewable energy in Westmeath.
It is considered that the Subject Lands represent the best possible opportunity for the strategic development of Athlone as one of the country’s leading Industrial and logistics centres. These lands present an opportunity to plan for the development of a world class hub for national and global corporations to base themselves in the midlands of Ireland with superb connectivity, infrastructure, available workforce and an attractive and affordable place to live for employees.
The subject lands present an opportunity to future proof Blyry Industrial Estate and bring it into the 21st century as a world class hub for business, enterprise and employment. Demand is there if adequate quantum of high-quality modern space is delivered by private interests working in tandem with the Local Authority and state agencies including the IDA and Enterprise Ireland – both based in Athlone.
It is considered that now is the right time to plan for the future growth of Blyry as the main enterprise and employment location in the midlands to help achieve the aims of the NPF and RSES and ensure Athlone delivers as the Regional Growth Centre for the Midlands.
it is submitted that the subject lands are appropriate, available, contiguous, accessible and most suitable for zoning for enterprise and employment uses under the new Westmeath County Development Plan.
Please see attached submission.
Please see attached
As attached
A walkway is needed to Lough Lene from Collinstown Village.
I suggest that this submission could be included in the Heritage Ch. The Moate Town Plan, Tourism Ch. and Economy Ch.
1. It is time to put a long overdue end to the use of the black cast iron and black plastic public bins. They are not environmentally or recycling friendly. They are an eye sore and at times stomach churning to look at to see affluent seeping down their sides and leaking from the bottom.
2. It is time to put an end to the tractor and open trailer method of collecting pub bottles. Every time these bottles are collected, leftover waste from the bottles leak from the trailer onto the streets of Mullingar and leave quite a stench. This then stains the roadways and is an eye sore to visitors and locals alike. Is this the image you want to be leaving international visitors?
3. Establishments, in particular nite clubs must take responsibility for their punters vomiting on the streets late at night. They must take care to clean said affluent in an environmentally friendly way and not to leave visible signs on public walkways.
4. It is also time to move away from the Purple Flag accreditation which is a British standard and replaced with a recognised EU standard.
5. Turf cutting/extraction from bogs and use as fuel must be banned with immediate effect.
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The tourism potential of the Greenways is enormous, particularly in the Mullingar, Multyfarnham, Coole, Castlepollard and other villages like Finnea and Streete in the greater north Westmeath area, which is fast becoming a de-facto cycling and walking hub. There is no reason why Westmeath can't benefit from a tourism and commercial perspective and accrue at least the benefits being seen by the Greenway in Mayo in the local economy. The Greenway will be an important national tourism asset, attracting walkers and cyclists from all over Ireland, Europe and beyond. It will also provide recreational opportunities for local communities along the route to grow and create much-needed employment in these forgotten black spots. The river inny is also a valuable assist to the north Westmeath section of our county which is not being utilised to its potential, the development of a blue way south of Lough Derravaragh could also connect the canal at ballynacargy with the Royal Canal Greenway which currently extends from the Meath/ Westmeath border to Abbeyshrule in Co. Longford and Centre Park at Ballymahon opening up endless possibilities. The river Inny north can connect Abbylara and Granard in North Longford and also Lough Sheelin at Finnea and further north to other greenway way possibilities.
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State agency Like Westmeath County Council, Waterways Ireland, in partnership with the national tourism development agency, could set out a tender for a project manager to work out how businesses in the area can best leverage the region’s assets and attract more holidaymakers. The Shannon River is the longest in Britain and Ireland at 360 km. The Inny River is its main tributary stretches 70 km’s and the very source of where life in the Shannon begins. The river Inny could be a world-class angling attraction, playing host annually to many local and international fishing competitions. It could also be linked to greenways and areas of historical significants.
I also ask that an area be considered for industrial development
We ask that this road be reviewed in the county development plan and is considered for upgrading. this road carries a high volume of traffic all year round and is a vital link as an emergency escape route for the N4 Mullingar to Edgeworthstown and N55 Cavan to Edgeworthstown. This road has been the scene of many minor accidents over the years in winter months; this could possibly have been avoided if the road had been gritted. This route has been recently highlighted as a necessary emergency route connecting north Westmeath and North Longford to the Cavan border. We wish to raise health and safety and wellbeing concern. This road was blocked by snow a few years ago by the adverse weather conditions. Due to an accident on the N55 Longford and Westmeath county council relied heavily on local farmers who used their machinery to open the road. We call Westmeath County Council for this road to be part of the winter road gritting and snow clearing plan.
Mullingar town is noted as a destination town for tourists. We would like to see Lough Lene, along with the Seven Wonders of Fore, the Nelly to Nancy walk in Fore and Tullynally Castle being focused on as a must see day trip from the destination town of Mullingar. This would help to bring more visitors to the area and would be a boost to the local area. This would also provide a wonderful day out for all those who visit Mullingar.
We would like to see safe pathways, trails or hard shoulders for a minimum of 2km on the approach to towns and villages. This facility would make it safe for children who live close to their town/village to cycle to school. People would be able to safely walk or cycle to the local shop for daily groceries and to do business locally. Short car journeys are bad for the environment, providing safe places for cycling and walking would encourage people to leave the car at home which would help reduce carbon emissions. This would also have huge health benefits as people would be more active.
The lands in control of Trenholm Ltd. represents a significant parcel of land very much associated with the Village, its future development potential, its ability to play a part in the rural and tourism economy of the County and as can assist in the key plan objective of presenting a consolidated form of development, via a specific community and tourist focus as will present opportunities for public realm and natural area enhancement.
In this regard and whilst acknowledging the lands may not be suitable for a specific zoning they potentially require a Specific Local Objective to facilitate the potential tourism economy of the land. The lack of Plan led objectives for this significant and important tourism venture (Mount Druid) have recently fallen foul of the planning authority in respect of an application for the provision of a restaurant offer on the Mount Druid Complex, similar to the Avoca model so successfully absorbed and interpreted in Co. Wicklow
Trenholm Ltd. – Site Specific Zoning Submission, seeking:
1. consideration of a change from a ‘proposed residential’ to a ‘Mixed Use’ Land Use Zoning designation on the Main Street, and
2. consideration of a ‘Specific Local Objective’ for Mount Druid
Request to provide more in-depth zoning for modest residential development in Glasson Village to meet the demand for housing in the area.
See Submission on change of zoning on Map 2 of the Draft CDP.
To note: The attached submission relates to all a number of chapters of draft Plan, including Climate Action. The Council is requested to review the submission in the context of all aspects of the draft Plan.
Streete is an area of historical importance and its community centre attracts people from as far away as Sligo, Dublin, Carlow and the northern counties through the year. Streete parish park Community Centre can see up to 1300 people cross the gates every week. The centre is renowned for its sporting activities and the annual vintage show which has taken place every year for the past 18 years along with a host of charity and social events. We ask that this vital informative signage be considered as a positive move forward in the County Development plan.
Please find attached the Agency's submission in relation to the Draft Westmeath CDP 2021-2027 and SEA ER.
ORS was engaged by Mrs. Phyllis O’Connor to make a submission on the Draft Westmeath County Development Plan 2021-2027. The submission relates to the zoning objective proposed for lands within a folio owned by Mrs. O’Connor. These lands were previously zoned for residential use up until 2014 and it is submitted that the current zoning objective is inappropriate and should be amended to provide greater use of the land to support the sustainable growth of this designated self-sustaining town.
We submit that the development boundary be altered to incorporate our client’s lands which are currently un-zoned. We also submit that these lands be zoned for residential use in order to facilitate the development of the site and enable the village to organically grow as a self-sustaining town.
We note policy CPO 8.155 of the draft development plan which seeks to identify suitable land for future residential development. It is our opinion that the subject lands are ideally situated to comply with this policy.
CPO 8.155
Make provision for sustainable communities in Killucan-Rathwire by identifying sufficient land for new development, in particular housing, commercial, community and recreational uses.
We suggest that a proportion of the remaining un-zoned area within the two land folios, WH28070F and WH23756F, of approximately 7.5 hectares be included in the Westmeath County Development Plan 2021-2027 for residential development use. We suggest that the southern boundary of our proposed area be kept in line with the existing boundaries of the residential sites in the village, which will add balance to the overall settlement.
Please refer to attached Submission.
Please find attached general obserations on behalf of Irish Water
Our Client is taking an innovative approach towards the planning, design and building of high-quality homes at densities consistent with the National Planning Framework (‘NPF’) and the Regional Spatial and Economic Strategy (‘RSES’). Such an approach is key to ensuring that suitable lands are developed in the most efficient and sustainable manner feasible, to meet known housing shortages and the aims and objectives of national policy and guidance to address same.
The RSES directs the policy response at a regional scale on how best to achieve the shared goals set out in the National Strategic Outcomes (‘NSOs’) of the NPF, specifically:
The amount and location of zoned lands in the Draft Plan seeks to accord with NPF and RSES, to promote consolidation of existing settlements and compact growth this is supported. The Housing Strategy correlates with the Core Strategy and is supported by the Housing Need Demand Assessment (‘HNDA’). The Strategy projects that an additional 4,983 residential units could be required in the Plan area over the Plan period and that in providing for this, “intensification in established urban areas and existing towns, through infill development and brownfield redevelopment, is a priority.”
The Draft Plan notes that the average household size is predicted to be 2.64 in 2027; a reduction from the 2.76 average recorded in the county during the 2016 census. Policy CPO 3.5 of the Draft Plan aims to “Ensure that a suitable variety and mix of dwelling types and sizes is provided in developments to meet different needs, having regard to demographic and social changes.” This recognition in the Draft Plan is welcomed. The changing household size and demographic will impact on the type of housing provided and to respond to these future changes, some degree of flexibility in planning and standards will be required.
In order to deliver high quality units whilst maintaining residential amenity, a new approach to housing design and the flexible application of development management standards will be required going forward. The new and innovative housing model proposed by our Client caters for the needs of different age profiles from those buying their first home to retirees all within the same development, reflecting the RSES and NPF. This submission to the Draft Development Plan presents an opportunity for the Planning Authority to ensure the correct policy framework is in place to allow this to happen on the ground.
It is noted that Planning Authorities and An Bord Pleanála are required to apply any specific planning policy requirements (‘SPPRs’) of the guidelines, within the meaning of Section 28 (1C) of the Planning and Development Act 2000 (as amended), in carrying out their functions. In that vein, the Urban Development and Building Heights Guidelines for Planning Authorities (2018) includes SPPRs relating to compact growth, densities and building typologies as follows:
SPPR4: It is a specific planning policy requirement that in planning the future development of greenfield or edge of city/town locations for housing purposes, planning authorities must secure:
1. the minimum densities for such locations set out in the Guidelines issued by the Minister under Section 28 of the Planning and Development Act 2000 (as amended), titled “Residential Development in Urban Areas (2007)” or any amending or replacement Guidelines;
2. a greater mix of building heights and typologies in planning for the future development of suburban locations.
In addition, Section 7.10 and 7.11 of the Sustainable Residential Development in Urban Areas Guidelines (2009) make clear how design should be utilised to achieve a strong development response:
“Qualitative standards should be the real test, and innovative design solutions which achieve good performance standards should be considered on their merits”.
“Innovative dwelling design should be encouraged in order to facilitate the potential future provision of adaptable and accessible accommodation”.
Our Clients response to these directions has been to devise a range of housing typologies which first and foremost provide sustainable, livable, welcoming and adaptive places to live. In doing so, compact growth is delivered along with a hierarchy of open spaces and environments which are not car-dominated. It is noted that the Draft Plan states that “positive urban placemaking and design is a central component in creating and sustaining vibrant towns and villages.” Our Client’s share this aim, prioritising positive placemaking and creating successful communities. New homes need to be flexible to meet the needs of a range of household types and sizes, and to meet individual households’ changing needs over time therefore a ‘one size fits all’ approach will not work into the future. Our Client’s approach accords with the thrust of national, regional and local policy, providing appropriate densities and tailored urban design can facilitate the framing of streets, enable the creation positive spaces and places and enhance community through the inclusion of shared surfaces which can give priority to the pedestrian. Own-door housing can provide for better consumer choice and a more viable product. The use of contemporary and innovative design solutions should be encouraged with a flexibility in the application of development management standards.
Development Management Standards
To deliver the NPF’s target of 30% of all new homes within the existing built-up areas, continue to promote compact growth and meet the Draft Plan’s aims of creating high quality vibrant settlements the Authority should give consideration to the following:
In order to achieve the aims of the Draft Plan while ensuring the resulting places created over the Plan period are fit for purpose, the Council’s policies and Development Management Standards “shall allow for a degree of flexibility, focusing on design led and performance-based outcomes, rather than applying absolute requirements in all cases.” This approach is supported. Our Client welcomes the translation of this sentiment into a Policy Objective CPO 16.1 of the Plan:
“Apply flexibility in the application of development standards with the consideration of performance-based criteria appropriate to general location, which will provide high-quality design outcomes, where appropriate. This more dynamic performance-based approach, applicable to town centre locations, will facilitate flexible design solutions in instances where a proposal fulfils specific planning requirements.”
16.2.1 Urban Design Principles
CPO 16.2 of the Draft Plan seeks to “Achieve the delivery of high-quality built environments ensuring that development is designed to a high standard in line with the Sustainable Residential Development in Urban Areas – Guidelines for Planning Authorities and Best Practice Urban Design Manual (DoECLG 2009), the ‘Urban Development and Building Heights Guidelines for Planning Authorities’ (2018), the core strategy for the county and other planning considerations.”
While this Policy is supported, we urge the Authority to amend the Policy with the addition of the following:
“In order to facilitate and encourage innovative design solutions, the Council will exercise flexibility in the application of the development management standards in instances where high quality design and layout has been demonstrated and subject to the maintenance of adequate privacy and protection of residential amenity.”
16.3.1 Design, Layout and Housing Mix
CPO 16.10 of the Draft Plan states that “Residential schemes to provide a range of dwelling sizes and typologies to accommodate emerging demographic trends in line with the Westmeath Housing Strategy and Housing Needs Demand Assessment or other evidence supported methodology. Proposals for residential schemes which are proposed on infill or smaller sites should demonstrate the ability of the proposal to provide a mix of dwelling types within the locality as opposed to within the scheme itself.”
We would seek clarification on what the Council consider “other evidence supported methodology.” It would be of use if the emerging Plan could outline the type of information which could be accepted by the Planning Authority.
CPO 16.11 of the Draft Plan states that “Planning proposals for housing schemes are required to present a considered design approach to tailor the scale, design, layout and density of housing in responding to the individual character of the respective town or village.”
Our Client supports the concept of a considered design approach having regard to the site context and in considering the principles of CPO 16.1
The physical, social and environmental criteria set out in CPO 16.12 with regards new housing layouts is acknowledged.
CPO 16.14 states:
Generally require a separation distance of 22m between opposing rear first floor
windows to avoid overlooking and protect private residential amenity. Innovative dwelling types, such as houses which have their main sleeping and living areas on one side, and circulation and bathrooms on the other, may allow for a reduction in this standard. Any window proposed at ground floor level should not be less than 1m from the boundary it faces.”
Glenveagh welcomes this CPO and would respectfully suggest that the wording should include flexibility in the interpretation of standards where innovate and well-conceived scheme are being proposed.
CPO 16.16 states:
“Incorporate Dual Aspect designs into residential schemes, where possible, to ensure provision of active and passive surveillance over street frontages, creation of attractive thoroughfares by avoiding spanning rear garden walls, the creation of more recognisable routes and junctions that aid navigation and contributing energy efficiency advantages, whilst providing for more attractive, usable and adaptable living spaces, and better sunlight/daylight provision to its occupants.”
In order to implement this policy a relaxation of Development Management Standards per CPO 16.1 requires to be referenced. The following additional wording is therefore proposed:
“It is acknowledged that to achieve this, some flexibility in the application of Development Management Standards per CPO 16.1 may be required.”
The discretion employed in CPO 16.18 Boundary Treatment with regards rear private gardens is welcomed and should be cross-referenced with CPO 16.1.
Similarly, with regards CPO 16.20 Private Open Space, the provisions for flexibility in the application of the policy is welcomed.
16.4.1 Parking Standards
With regards parking standards, the Draft Plan Policy CPO 16.35 aims to “facilitate a modal shift towards more sustainable forms of transport” and requires, per associated Table 16.3, that planning applications for residential development provide:
With regards visitor parking, the following thresholds apply:
Our Client fully supports the aims at various tiers of the planning hierarchy to reduce car dependency, acknowledging the modal shift to more sustainable means of transport is required to assist in meeting climate change and zero carbon targets. That said, there is a commercial reality which needs to be considered as part of this discussion and one which cannot be ignored. It is the case that in this country there are numerous large towns and indeed suburbs which are not served well by public transport, the result of which is a higher rate of car dependency in homeowners. Coupled with the fact that typically both adults in an average household work, and that children are living at home longer, means that there may be occasions where the thresholds set out in Table 16.3 cannot be met in full. We would therefore encourage the Council to address this issue at this stage by building-in some flexibility to Policy CPO 16.35 as follows:
“Assess all planning applications for development having regard to the car parking requirements set out under Table 16.2 below. Any deviation from these standards will require to be fully justified by the Applicant.”
General Comments
A provision within the Development Plan is requested that facilitates this innovative design and that meets the following suggested performance criteria:
This submission requests that Westmeath County Council gives further consideration to the ability of Development Management Standards to include a degree of flexibility with regards residential schemes in the context of layout, separation distances and private open space requirements, in order to give developers and the Council the tools to achieve the policy objectives set out across all tiers of the planning hierarchy.
In conclusion, it is respectfully requested that Westmeath County Council include in their Development Plan the above recommendations with respect to development management standards and ensures the emerging Plan provides a strong yet flexible planning framework for future growth.
As part of this process, it is considered that engagement with the housebuilding sector is critical to ensure a fit for purpose Plan exists going forward and on behalf of our Client welcome the opportunity to engage with the County Council to discuss in more detail the innovative housing models being progressed.
Request to zone lands for low scale residential development (see attached map) at Mount Temple, Co. Westmeath
Request that the individual listing of the property be deleted and that adequate protection could be afforded to the structure if it was included in an Architectural Conservation Area in this street location.
This submission is made on behalf of the registered owner of Folio No WH22227F and seeks the rezoning for residential purposes of lands in Clonmellon, Co. Westmeath, which were previously zoned for development and planning permission granted for residential development.
The purpose of this submission is to respectfully seek the designation of the subject lands as available to the Glasson Rural Serviced boundary as may be suitably extended within the Draft Westmeath County Development Plan 2021-2027. The location and extent of the subject lands, which is in the ownership of Andrews Construction Ltd, and is identified within Figure 1.1, below.
Athlone is identified as a Regional Growth Centre and as such the hierarchy of settlements as support the Regional Growth Centre should be considered to support the ‘Strategic’ growth of the Rural Environs of Athlone.
The subject lands should be included in the Glasson Rural Serviced zoning boundary and be designated as Proposed Residential Land Use Zoning as it will allow for sustainable and consolidated growth of the community in Glasson
The Draft Westmeath County Development Plan 2021-2027, has zoned the subject lands as Consolidation Site and the purpose of this Land Use Zoning is: CPO 15.5 Strengthen and consolidate existing settlements by encouraging the development of infill and brownfield lands through providing for a range of uses including residential development, retail, commercial and community uses.
Whilst we welcome and respect the planning authority's consideration of the subject lands for a development zoning to strengthen and consolidate the existing settlement of Killucan, we consider and respectfully suggest that a more appropriate zoning in the circumstances would be zone the subject lands as Proposed Residential.
MMA Architects were engaged by Adah Cuffe of Ballymore, Co. Westmeath to make a submission on the Draft Westmeath County Development Plan (CDP) 2021-2027. The submission relates to the zoning objective of lands. It Is submitted that the current exclusion of these lands from the development boundary, is inappropriate for a central location in a Rural (Serviced) settlement. Below we outline in detail the planning and zoning history of the lands, and the proposed zoning request.
The submission relates to a zoning request for lands at Townparks, Castlepollard. These lands were previously zoned for residential use up until 2014, and it is submitted that it is now appropriate to zone the lands 'Proposed Residential' use to facilitate the town’s growth as a self-sustaining principal town and main service centre for North Westmeath.
Delete Lough Sheever Fen/Slevin's Lough complex from the proposed Natural Heritage Area. This proposal will affect the existing usage for all purposes, of the adjoining and surrounding private lands to the proposed area.The proposed Natural Heritage Area will affect the existing established grazing, access and usage rights which are currently enjoyed over this area.The boundaries of proposed Natural Heritage Area on Map No 38 have not been defined and not agreed with adjacent land owners.
CPO 7.2 pertains to key attributes to be considered in public realm and public space enhancements – namely – they must be accessible, functional, and attractive. I would like to submit the observation that the new public seating in the Market square in Mullingar fails on all three attributes and I would describe it as ‘hostile’ street furniture. The black metal seating has no back support – it is a bench style seat which has metal divisions along its length. Such divisions are considered to be devices to ensure that people do not stay seated for too long. I would argue that this style of seating – without back support is not comfortable or safe for older people and those with balance issues. The divisions also create difficulty for larger people. I have two family members with mobility issues, and it is our personal experience that in general, there is a dearth of public seating in our towns and villages. I would welcome an objective to significantly increase the stock of public seating across the county and to ensure that it is actually accessible, functional, and attractive.
In relation to CPO 12.37 and 12.38 – which pertain to the protection of trees during new developments - I welcome this objective however I wish to make the following observation. During the Mullingar Town enhancement works – a number of mature trees were removed. To date – these have not been replaced. The original plans for the town enhancement works included several trees in Market square and elsewhere. These have not been provided. The large black plant containers which are currently in place around the town of Mullingar are a poor substitute for permanently planted trees, in my view. Apart from the visual appeal of green infrastructure – providing trees in town centres has a health & safety benefit. The Westmeath County Council Climate Change Adaptation Strategy includes a commitment for the provision of trees to provide shade to alleviate heat stress. I would ask that the new County Development Plan includes a commitment to significantly increase, as soon as possible – the amount of appropriate tree cover in all towns and village centres across Westmeath. If we were to take this action now - in 10-15 years Westmeath could be renowned for our beautiful tree-lined villages and towns.
Peatlands – I welcome the inclusion of CPO 12.58 Exercise control of peat extraction, both individually and cumulatively, which would have significant impacts on the environment. The NGO “Friends of the Irish Environment” have documented numerous incidents of unlicensed extraction of peat from bogs in Westmeath for many years now – and it seems that Westmeath County Council, NPWS and the EPA have not managed to get control of these activities which have resulted in the destruction of many beautiful bogs around the county. My observation on this issue is that – unless there is a new objective spelling out what real and meaningful action Westmeath County Council propose to take going forward to gain control of this activity – that objective CPO 12.58 is unlikely to be realised
CPO 13.19 Protect High Amenity areas from inappropriate development and reinforce their character, distinctive and sense of place.
CPO 13.21 Protect lakeshores from any inappropriate development which would detract from the natural amenity of the area.
In relation to these two objectives - I understand that councilors recently passed a motion to make a number of changes to some of the high amenity areas in Westmeath. I would like to express my opposition to any such change without proper public consultation in advance to enable appropriate assessment by qualified experts, appropriate bodies, and the general public. In my view councilors are not properly qualified to assess the impact of any changes to high amenity areas. Any changes made without public consultation is likely to be resisted by the public and by NGOs – and any subsequent attempt to develop these areas is likely to be met with a significant number of objections. I therefore wish to submit the observation that there should be no changes to areas designated as High Amenity areas without an appropriate period of public consultation.
Westmeath has only 3 designated swimming areas. This summer it became clear that our swimming areas were barely able to cope with the crowds of people attending during the lockdown. Apart from CPO 13.30 – there does not appear to be any clear provision in the county development plan for the creation of new swimming areas to ease the pressure on these 3 amenities. The area around the diving board at Lough Owel is not sufficient for the numbers using this area in summer. Night-time parties at Lough Owel, Lough Ennell and Captain’s Hill - and the litter left after these gatherings has been a significant issue this summer – one that if not addressed will result in families and tourists avoiding these amenities in future. There is also a significant issue of plastic pollution in the water at Lough Owel, which is a problem from those swimming there year round. The new County Development plan should include objectives to address these issues.
For too long our great county's reputation has been tarnished by the likes of Niall Horan and Michael O'Leary. For too long our GAA has suffered. Enough is enough. It is time to admit defeat and once again unite with our eastern brethern. Together, we can overcome these difficult times and face any adversities. Together, we will free ourselves from Anglo-Norman division and return Meath to its former glory, Big Meath. An Mhí Mhór Abú.
We hereby call for a public referendum on the reunification of Meath, it's time to put it to the people.
Chapter 2 - Core Strategy, Population Projection Mullingar
Chapter 5 - Economy and Employment - Understatement of employment opportunities in Mullingar
Re: Draft County Developement Plan 2020.
Dear Sir/Madam,
I have reviewed the recent Draft of the County Development Plan (hereinafter called "the draft") and wish to make the following comments and suggestions, which I have placed in sequential order for your ease of reference:
- 1. Uisneach:
While I note that Uisneach has now been listed as an archaelogical setting with specific zones of protection in the draft, I note that these zones are limited to the circumference of the hill itself. These zones do not extend beyond the hill to the panoramic views from the summit of the hill, which are an intrinsic part of the value of this setting.
Similarly, I also note that the draft refers to the placement of Uisneach on the U.N.E.S.C.O tentative list however the draft fails to afford the setting any of the protections which this setting of both national and international renown would require, in advance of this nomination process.
I also note that the Uisneach landscape policies contained in our current Plan are now re-listed as policy objectives. This appears to be an unnecessary adjustment to the clearly defined policies in our current Development Plan.
On this basis, I am now seeking that the current policies for Uisneach , which are now listed as policy objective numbers 13.17 and 13.18 are reaffirmed as policies.
Furthermore, I am also seeking the insertion of a policy to ensure the sensitivity of this historic setting is maintained, namely that the precautionary principle is applied prior to the grant of any premissions:
Suggested Additional New Policy for Uisneach:
“As a landscape of both national and international renown, it is a policy of Westmeath County Council to apply the precautionary principle and ensure that the setting of the Hill of Uisneach and its associated zones are maintained and enhanced in advance of any formal nomination and or preparation of a management plan. In advance of any formal grant of planning permission, Westmeath Co Council will apply the zone of theoretical visibility including reverse zones as defined in the International U.N.E.S.C.O Guidelines, to define where development would not normally be permitted due to the sensitivity of the setting and its associated zones; Development will be subject to scrutiny in terms of its impact on the setting of the Hill of Uisneach.”
2. Industrial Scale Wind Farms and associated Wind Energy Maps:
I note that the western lowlands, namely area 7 is being rezoned as a landscape area which may have capacity for wind energy as opposed to other areas within Westmeath. I note there is no justification or explanation for this re-zoning within the draft plan.This rezoning is a contradiction of Policy P-Win 2 in our current Development Plan which strictly directs Industrial Scale Windframs to areas of cut away bogland.
Also, I must question why the new wind energy policy, which is now called policy objective 10.135 in the draft, dilutes the original terms of P-Win 2, which strictly directs industrial windfarms to cut away bogs.
I note that policy objective 10.135 indicates that the council will "encourage" rather than "shall strictly direct" industrial scale windfarms to cut away bogs.
I also note that the criteria to determine industrial scale windfarms in policy objective 10.135 is also ambiguous. It omits the word "or" from the three alternative criteria which identify industrial windfarms.
In this regard, I do not accept that area 7 should be rezoned on the wind energy maps and I am also seeking the full re-instatement of Wind Energy Policy P- Win 2 from the current Development Plan without amendment.
3. Noise Pollution:
I note that policy objective 10.123 in the draft requires all development to be designed and operated in a manner that will minimise and contain noise levels in accordance with Noise regulations. I would suggest that the actual noise regulations should be defined to avoid any ambiguity in the plan.
In this regard, I would suggest the following additional wording for 10.123 as a policy which
Requires all development to be designed and operated in a manner that will minimise and contain noise levels in accordance with World Health Organisation's 2018 Environmental Noise Guidelines (as may subsequently be amended).
I would also question the ambiguity in policy objective 10.136 that the council should ensure that proposals for either energy development demonstrate that human health has been considered, including those relating to the topics of:
(a) Noise (including consistency with the World Health Organisation’s 2018 Environmental Noise Guidelines for the European Region)
It is not an adequate policy objective to simply "consider" issues of human health.
Policy 10.123 should require all energy developers or transmitters to comply with W.H.O Guidelines. Health protection should be a policy requirement which underpins all schemes for energy development/transmission.
I would also suggest the following new wording for 10.136 (a) as follows:
It is a strict policy of Westmeath County Council that all proposals for energy development and or transmission comply with World Health Organisation Guidelines including those relating to the topics of:
(a) Noise (including consistency with the World Health Organisation’s 2018 Environmental Noise Guidelines for the European Region) and are managed and assessed by the energy developer on a ongoing basis by the developer using B.A.T (Best Available Technology as defined by Section 5 in the EPA Act 1992) in accordance with the W.H.O Guidelines and Environmental Noise Directive 2002/49/EC.
5:Set Back Distances:
5. I note that 10.132 recommends set back distances for "wind turbine generators" according to specific heights. However the heights aren't adequately defined. Considering the scale and height of both the turbines and their blades, this height should be described according to the height of the wind turbine generator including the height of their blade.
Landscape, Lakes and Areas of High Amenity:
6. I must question the proposed amendments of the existing policies for the lakes in the current Development Plan to policy objectives in the draft, considering the national renown of Westmeath as the "Lake County". The differing lakes form an essential mosaic of areas of high amenity value throughout the county, from Lough Ree in the west to Lough Derreveragh in the North and Loughs Owel and Ennell in the heart of the County.
These policies for the lakes are essential to protect these unique landscape resources. Their associated high amenity status is also intrinsic to the human enjoyment of these natural resources within the county. Our current Development Plan provides a clear distinction between the differing policies and objectives for the lakes. I do not accept any justification for amending or altering the status of these policies in the draft Plan.
In essence, I do not accept there is any justification for the amendment of all the landscape policies and amenity policies in Chapter 13 of the draft Plan.
I also note that proposed policy objective 13.11 requires a visual impact assessment for proposed developments with the potential to impact on significant landscape features within the county.
I would submit that a visual impact assessment is a superficial assessment of development, a more rigorous landscape assessment should be utilised in accordance with national guidelines.
I would suggest the following change to policy objective 13.11:
It is a policy of Westmeath County Council to require landscape and visual impact assessment for significant developments within the County and or developments with the potential to impact on significant landscape features within the county.
Furthermore, I note that the relevant assessment guidelines are also omitted in the proposed draft. The guidelines which underpin such assessments should be in accordance with the standards which are typically applied by An Bord Pleanla.
Suggested New Additional Policy: "The undertaking of landscape and visual impact assessments should be carried out in line with the Guidelines for Landscape and Visual Impact Assessment, 3rd Edition, 2013 issued by the Landscape Institute and Institute of Environmental Management and Assessment (IEMA) and any superceeding guidelines which the IEMA may issue. The Landscape and Visual impact assessment should address all elements of the proposed development including related infrastructure."
In summary, I am seeking the re-instatement of all the aforementioned policies in the current Development Plan together with an improvement on the existing policies for both Uisneach, the lakes, the landscape and health protection particularly in relation to the areas of either energy development or transmission.
Yours sincerely,
Emily Wallace
Councillor.
The submission has been prepared having regard to the tourism profile of the County; the existing policy context in the Draft Plan; and an established template for sustainable tourism policies being used by Fáilte Ireland to guide Planning Authorities.
For ease of reading, we have structured this submission as follows:
Please see added attachment for full details of the submission.
The purpose of this submission is to seek full designation of the subject lands to Proposed Residential zoned land within the Draft Westmeath County Development Plan 2021-2027 – Map 6 Kinnegad Zoning Map. Whilst we note and welcome part of the lands in the ownership of the Client are confirmed Proposed Residential we seek the entirety of the lands be afforded such designation. The location and extent of the subject lands, which are in the ownership of Andrews Construction Ltd., and are identified within Figure 1.1, below.
The Subject lands as a unified entity which are located within the Development Boundary of Kinnegad, to be zoned for Proposed Residential Land Use Zoning, having regard to the local character of the village, the location of the land and the surrounding area.
EirGrid comments on Chapter 10
Our submission on access to the countryside has been sent as an attachment
Please see cover letter attached
HI
The zone of the high amenity area is very vast - my lands marked on the interactive map have no view of the lake and no surface water flow to lake - there is a road way between my lands and the lands that run to the lake edge. Therefore I would like to remove my lands from the high amenity zone
Westmeath County Council, Planning Section, Áras An Chontae, Mount St, Mullingar, Co. Westmeath
12th May 2020
Re: Draft County Development Plan 2021 – 2027
Dear Sir / Madam,
We hereby submit observations and comments on the “Draft County Development Plan 2021 – 2027” and, in particular, relating to lands in Kinnegad. This submission is made on behalf of our client Mr. John Gildea. Mr. Gildea is a business and land owner in the town and in 2009/2010 developed the Primary Care Centre in Kinnegad on his lands. Mr. Gildea and his family are also residents, within walking distance of the town.
Specifically, the lands to which this submission relate are as outlined in red on the attached map (Appendix A). These lands are zoned “open space” on the current “Draft Development Plan 2021 – 2027. These lands are partially within a flood risk zone as set out on the OPW Preliminary Flood Risk Assessment (PFRA) maps. A detailed interrogation of the available flood risk information by ORS Engineers concludes that “the land zoning in this area was based on the flood extents, now considered overly conservative” and that “a case can be made for rezoning of these lands”. A copy of the ORS report is also attached. Mr. Gildea was born in Kinnegad, and has lived in the area all of his life, neither he nor any members of his family, or any other people he has consulted with in Kinnegad have any memory of the lands in question having ever being subjected to flooding. Mr. Gildea is also aware of other lands in Kinnegad, located close to the subject site that were also previously zoned as open space because they too were located within a flood risk zone. Upon submission of a flood risk report which demonstrated that the risk of flooding was thought to be highly unlikely Westmeath Co. Co. approved the process of altering the zoning on these lands. It is hoped that this precedent will be repeated on the site this submission relates to.
The “Draft County Development Plan” sets out general “Land Use Zoning” policies and objectives in Chapter 15, “Urban Centres and Placemaking” Policies and objectives more specific to Kinnegad are set out in Chapter 8, sub chapter 8.3.3. It is considered that the application of the general policies and objectives to the subject lands, taken together with the ORS study conclusion might inform the Kinnegad specific policies and objectives relevant to the lands, resulting in a zoning more appropriate than “open space”.
General “Land Use Zoning” (Draft CDP) objectives “aspire to promote orderly development” and “support the reusing of brownfield land, infill sites and underutilised lands in towns and villages”. The subject lands directly abound the present and historic town core to the south and are bounded by the Clonard river further south and east. To the west is the Aldi Supermarket. The lands by virtue of their proximity to the town core being enclosed by the Clonard river and the R446 and the Aldi Supermarket site could reasonably be considered “underutilised” or “infill”. CPO 15.9 (Draft DCP) states that “it is a policy of Westmeath County Council to provide for, protect and strengthen the vitality and viability of town centres, through encouraging a mix of uses and maximising the use of land”. We contend, that the subject lands zones as “open space” would be contrary to this policy. A logical sequential approach to the zoning of Kinnegad might suggest that the areas to be zoned should be contiguous to the existing zoned land.
The development of the subject lands would be cost effective in terms of access to drainage infrastructure and other services and could positively contribute to the vitality and viability of the town core making it conducive to being zoned other than “open space”.
CPO 2.15 would add further weight to an alternative zoning to the subject lands as it states that the policy is to “support the regeneration of underused town centre and brownfield, infill lands along with the delivery of existing zoned and services lands to facilitate population, growth and achieve sustainable compact growth tagets of 30% of all new housing to be built within an existing urban footprint of targeted settlements within the county”.
Many of the Draft CDP policies specific to Kinnegad might also, when applied to the subject lands, suggest a zoning other than ”open space” is appropriate. The relevant policies are as follows:
CPO 8.84 facilitate the expansion of the range of services and facilities available to residents and the wider rural hinterland, CPO 8.85 support the regeneration of infill and brownfield sites in the town core and seek to achieve sustainable compact mixed use development at these locations based upon the principles of good urban design and place – making.
CPO 8.86 provide for the creation of sustainable communities in Kinnegad by identifying sufficient land for new development, in particular housing, enterprise and employment, community and recreational uses.
CPO 8.89 support the consolidation and growth of existing enterprises and development of employment opportunities with the town.
CPO 8.94 Encourage the appropriate redevelopment of brownfield and infill sites for residential uses within the footprint of the existing built up area.
CPO 8.96 provide for the expansion and development of educational, social, community and recreational facilities in the settlement.
CPO 8.101 support Kinnegad as an Age Friendly Town and ensure that new developments are designed to meet the needs of older persons.
CPO 8.102 support the development of housing for older persons within Kinnegad and its environs.
CPO 8.105 reinforce the centre of Kinnegad as the priority location for new commercial and retail development, with quality of design, positive contribution to the existing streetscape, and integration/linkage with the town core being the key underpinning principles in the expanded mixed use town area.
CPO 8.106 support the provision of mixed use developments in the town centre which create opportunities to live, work, shop etc within the town and reduce the propensity to travel by private car. CPO 8.107 encourage and facilitate the re – use and regeneration of derelict land and buildings for retail and other town centre uses.
CPO 8.108 support the development of under – utilised lands between the Inner Relief Road and the Main Street with appropriate mixed – use development with pedestrian / vehicular links to the Main Street.
Considering the above the following points would also be given due regard:
- A demand exists for the expansion of services and facilities offered at the Primary Care Centre. This would require extending this building and ancillary buildings, parking etc. the proposed “open space” zoning constricts this. - The subject lands are unsuitable for agricultural or similar open space uses and lie dormant and underutilised. - Some of the lands, considering their proximity to the town core and the Primary Care Centre may be suitable for development as age friendly housing. - Development of the lands may present an opportunity to develop a linear landscaped walkway along the river bank with buildings offering passive surveillance of same. - Development of the lands would offer opportunity to create further additional pedestrian permeability connecting the larger supermarket developments with the southeastern town core. - Development of the lands would improve the vitality of the southeastern town core and enhance opportunities for the regeneration of this area. - As part of any development of the lands an opportunity to enhance the gateway to the town at the Kinnegad bridge through the creation of a building or landscape feature of exceptional quality might be appropriate.
In summary, considering that the subject lands are not of significant risk of flooding, are extremely well served by existing services, are underutilised and through their development would offer considerable opportunity to enhance the south eastern town core we hereby request that due consideration be given to the application of a zoning use more appropriate than “open space” in the County Development Plan 2021 – 2027.
Yours faithfully,
Garvan Hanley, MRIAI, RIBA, Registered Architect, Hanley Taite Design Partnership
The submission welcomes and endorses the ‘Opportunity Site’ designation and the capacity of the site to deliver a regenerative and consolidatory form of development to allow the best use of urban lands in the interests of Kinnegad a Self-Sustaining Town as identified in the Settlement Strategy.
In this regard MOLA Architecture herein present a visioning exercise as presents a deliverable model and form of development as could endorse the Zoning & Objectives designations afforded the lands.
Perception of ‘Mixed Use’ as Commercially Biased
Notwithstanding the over-riding support of the designation herein we highlight that appropriate flexibility be applied to the weight and balance of the intended mix of uses on a site by site basis. In effect, we respectfully contend that the balance of deliverable uses in this instance and on the basis of significant retail standalone uses surrounding the subject lands and the levels of vacancy in the main street, a predominant residential development provides the best viable and deliverable development in this instance and as portrayed within the associated ‘visioning’ and masterplanning’ exercise herein presented.
The current Expanded Settlement Zoning Objective at 15.12 of the Draft WCDP may for example be interpreted as led by a commercial and retail bias with residential uses providing a supporting role and as could in the subject instance seek to present potentially inflexible and non-viable uses where substantive provision of retail and commercial already exists both active in the form of Aldi/Tesco and inactive in the form of vacant units in the Main Street.
Submission attached on behalf of An Post.
Please see attached report.
Please acknowledge receipt of our submission
Please see attached letter
I have suggested some draft policies.
As per submission pdf attached
SUBMISSION TO THE DRAFT WESTMEATH COUNTY DEVELOPMENT PLAN 2021-2027 IN RESPECT OF LANDS AT MULLINGAR ROAD, KILLUCAN, CO WESTMEATH
Collinstown Village is but one example of a village where the speed limit of 50km is constantly ignored. The long straight road through the village means, that despite a speed limit of 50km, traffic, including large lorries do not slow down at all when travelling through the village. The main Castlepollard to Delvin road is a "R" regional road and as such speed bumps and other measures are not currently possible on this road. Policy needs to be introduced allowing for necessary traffic calming measures to be allowed and encouraged on all roads in towns and villages in line with the speed limits in place in those areas. If traffic is only supposed to be travelling at 50km then surely these kinds of traffic calming measures should be safe, regardless of the status of the road.
Collinstown needs to be looked at as a high priority for traffic calming measures.
Re: Draft County Developement Plan 2020.
Dear Sir/Madam,
I have reviewed the recent Draft of the County Development Plan (hereinafter called "the draft") and wish to make the following comments and suggestions, which I have placed in sequential order for your ease of reference:
- 1. Uisneach:
While I note that Uisneach has now been listed as an archaelogical setting with specific zones of protection in the draft, I note that these zones are limited to the circumference of the hill itself. These zones do not extend beyond the hill to the panoramic views from the summit of the hill, which are an intrinsic part of the value of this setting.
Similarly, I also note that the draft refers to the placement of Uisneach on the U.N.E.S.C.O tentative list however the draft fails to afford the setting any of the protections which this setting of both national and international renown would require, in advance of this nomination process.
I also note that the Uisneach landscape policies contained in our current Plan are now re-listed as policy objectives. This appears to be an unnecessary adjustment to the clearly defined policies in our current Development Plan.
On this basis, I am now seeking that the current policies for Uisneach , which are now listed as policy objective numbers 13.17 and 13.18 are reaffirmed as policies.
Furthermore, I am also seeking the insertion of a policy to ensure the sensitivity of this historic setting is maintained, namely that the precautionary principle is applied prior to the grant of any premissions:
Suggested Additional New Policy for Uisneach:
“As a landscape of both national and international renown, it is a policy of Westmeath County Council to apply the precautionary principle and ensure that the setting of the Hill of Uisneach and its associated zones are maintained and enhanced in advance of any formal nomination and or preparation of a management plan. In advance of any formal grant of planning permission, Westmeath Co Council will apply the zone of theoretical visibility including reverse zones as defined in the International U.N.E.S.C.O Guidelines, to define where development would not normally be permitted due to the sensitivity of the setting and its associated zones; Development will be subject to scrutiny in terms of its impact on the setting of the Hill of Uisneach.”
2. Industrial Scale Wind Farms and associated Wind Energy Maps:
I note that the western lowlands, namely area 7 is being rezoned as a landscape area which may have capacity for wind energy as opposed to other areas within Westmeath. I note there is no justification or explanation for this re-zoning within the draft plan.This rezoning is a contradiction of Policy P-Win 2 in our current Development Plan which strictly directs Industrial Scale Windframs to areas of cut away bogland.
Also, I must question why the new wind energy policy, which is now called policy objective 10.135 in the draft, dilutes the original terms of P-Win 2, which strictly directs industrial windfarms to cut away bogs.
I note that policy objective 10.135 indicates that the council will "encourage" rather than "shall strictly direct" industrial scale windfarms to cut away bogs.
I also note that the criteria to determine industrial scale windfarms in policy objective 10.135 is also ambiguous. It omits the word "or" from the three alternative criteria which identify industrial windfarms.
In this regard, I do not accept that area 7 should be rezoned on the wind energy maps and I am also seeking the full re-instatement of Wind Energy Policy P- Win 2 from the current Development Plan without amendment.
3. Noise Pollution:
I note that policy objective 10.123 in the draft requires all development to be designed and operated in a manner that will minimise and contain noise levels in accordance with Noise regulations. I would suggest that the actual noise regulations should be defined to avoid any ambiguity in the plan.
In this regard, I would suggest the following additional wording for 10.123 as a policy which
Requires all development to be designed and operated in a manner that will minimise and contain noise levels in accordance with World Health Organisation's 2018 Environmental Noise Guidelines (as may subsequently be amended).
I would also question the ambiguity in policy objective 10.136 that the council should ensure that proposals for either energy development demonstrate that human health has been considered, including those relating to the topics of:
(a) Noise (including consistency with the World Health Organisation’s 2018 Environmental Noise Guidelines for the European Region)
It is not an adequate policy objective to simply "consider" issues of human health.
Policy 10.123 should require all energy developers or transmitters to comply with W.H.O Guidelines. Health protection should be a policy requirement which underpins all schemes for energy development/transmission.
I would also suggest the following new wording for 10.136 (a) as follows:
It is a strict policy of Westmeath County Council that all proposals for energy development and or transmission comply with World Health Organisation Guidelines including those relating to the topics of:
(a) Noise (including consistency with the World Health Organisation’s 2018 Environmental Noise Guidelines for the European Region) and are managed and assessed by the energy developer on a ongoing basis by the developer using B.A.T (Best Available Technology as defined by Section 5 in the EPA Act 1992) in accordance with the W.H.O Guidelines and Environmental Noise Directive 2002/49/EC.
5:Set Back Distances:
5. I note that 10.132 recommends set back distances for "wind turbine generators" according to specific heights. However the heights aren't adequately defined. Considering the scale and height of both the turbines and their blades, this height should be described according to the height of the wind turbine generator including the height of their blade.
Landscape, Lakes and Areas of High Amenity:
6. I must question the proposed amendments of the existing policies for the lakes in the current Development Plan to policy objectives in the draft, considering the national renown of Westmeath as the "Lake County". The differing lakes form an essential mosaic of areas of high amenity value throughout the county, from Lough Ree in the west to Lough Derreveragh in the North and Loughs Owel and Ennell in the heart of the County.
These policies for the lakes are essential to protect these unique landscape resources. Their associated high amenity status is also intrinsic to the human enjoyment of these natural resources within the county. Our current Development Plan provides a clear distinction between the differing policies and objectives for the lakes. I do not accept any justification for amending or altering the status of these policies in the draft Plan.
In essence, I do not accept there is any justification for the amendment of all the landscape policies and amenity policies in Chapter 13 of the draft Plan.
I also note that proposed policy objective 13.11 requires a visual impact assessment for proposed developments with the potential to impact on significant landscape features within the county.
I would submit that a visual impact assessment is a superficial assessment of development, a more rigorous landscape assessment should be utilised in accordance with national guidelines.
I would suggest the following change to policy objective 13.11:
It is a policy of Westmeath County Council to require landscape and visual impact assessment for significant developments within the County and or developments with the potential to impact on significant landscape features within the county.
Furthermore, I note that the relevant assessment guidelines are also omitted in the proposed draft. The guidelines which underpin such assessments should be in accordance with the standards which are typically applied by An Bord Pleanla.
Suggested New Additional Policy: "The undertaking of landscape and visual impact assessments should be carried out in line with the Guidelines for Landscape and Visual Impact Assessment, 3rd Edition, 2013 issued by the Landscape Institute and Institute of Environmental Management and Assessment (IEMA) and any superceeding guidelines which the IEMA may issue. The Landscape and Visual impact assessment should address all elements of the proposed development including related infrastructure."
In summary, I am seeking the re-instatement of all the aforementioned policies in the current Development Plan together with an improvement on the existing policies for both Uisneach, the lakes, the landscape and health protection particularly in relation to the areas of either energy development or transmission.
Yours sincerely,
Cllr Andrew Duncan,
7.0 submission proposals:
Draft Westmeath County Development Plan 2021-2027:
7.1 Submission Issue No.1: Strategic Road Link, under the Athlone Town Development Plan
7.2 It is submitted the Strategic Road Link indicated in a blue broken line on the Strategic Transportation Plan under the Athlone Town Development Plan 2014-2020 is a town planning category of planning objectives on a development plan or local area plan of this that are of a purely indicative nature, and while the local area plan support the in principle provision of a link road, that the broken blue line and its potential route are of a purely indicative nature and remains fully subject to future detailed alignment, detailed design and land procurement and availability.
7.3 Town Planning methodology and the accepted statutory legal position related to the indicative road zoning objectives is that the development plan or local area plan support the principle a future road but that the planning objectives is not specific to the land on which is indicated as it is subject to relocation, actual alignment, future detailed design, land agreement or expropriation of property once the road is subject to local authority funding, has been subject to detail Engineering FEED (Front End Engineering Design) design, under which final alignment has been achieved, followed by final design and construction drawings. The alignment in turn will not be final until it has been subject to full environmental assessment and environmental Appropriate Assessment which may again result and a deviation of location, route and alignment of the future Strategic Road Link.
7.4 In this context it is not acceptable that attempts are made through a subsequent plan such as the Cornamagh LAP July 2009 to effectively zone an indicative road, alignment as if it is a final alignment when a final alignment does not yet exist. It would appear that the planning confuses an indicative urban design masterplan type plan with a statutory zoning plan, the first being indicative consistent with an indicative road and the second being a statutory plan that fixes zoning location.
7.5 It is further of serious concern that the mentioned local area plan goes even further and indicates road zoning for Open Space and Road alignment outside of its study area and statutory jurisdictional area on plots of land and the subject site that is in the rural county area. This is completely unacceptable without any statutory basis of statutory effect.
7.6 It is however very damaging to the subject site’s market value, restricting its existing residential land use at this location and restricting its statutory development rights under its zoning category of “Rural Areas under Strong Urban Influence”, owned by a local man and local family with long established ties to the area and community, qualifying under the rural development policy for rural development.
7.7 Submission Issue No.2: Indicated Zoning by Cornamagh LAP July 2009 outside of its statutory jurisdiction.
7.8 It is submitted that it is significantly unsubstantiated and without a statutory basis or effect that subject site has previously been presented as if zoned for an “Open Space and Road” on Map 13: Zoning, Cornamagh LAP July 2009. Neither is there any basis for the inclusion of the subject lands in the Map 14: Development Framework, when the subject land fell outside of the study area, statutory jurisdiction of the Athlone Development Plan and the Cornamagh LAP. It is submitted that this error must urgently be corrected under the Draft Westmeath County Development Plan, and that any continuation on the basis of this misleading and statutory unsubstantiated presentation of the subject lands under the draft Westmeath Plan and its objective of a future Athlone Urban Development Plan (local area plan) or a future Cornamagh LAP under the mentioned future urban development plan should be critically avoided, and will be subject to serious objection by the owner of the land if this eventually did transpire. The land owner is seriously concerned about the potential impact that this misrepresenting of zoning, will have on the lands existing statutory development rights under the existing Westmeath County Development Plan and the Draft Westmeath County Development Plan’s rural development policy, rural enterprise and agricultural development policies and provisions, as well as the impact on its land value.
7.9 Submission Issue No.3: Recognition of existing and legitimate expectation of Rural Development rights under the Local Needs Policy
7.10 It is submitting that the draft Westmeath County Development Plan 2021-2027 correct the injustice of the indication in error and outside of the statutory plan area and statutory jurisdiction of the Athlone Town Development Plan and the Cornamagh Local Area Plan that to present the subject land as if zoned for “Open Space and Road” when there is no statutory basis for it. Recognition needs to be had for what the damage this error has caused to the subject site property’s market value, usability for residential, commercial or agricultural uses under its existing statutory developments rights of a land uses as the residential amenity of an existing dwelling and lands subject to the rural development policy under the existing Westmeath County Development Plan 2014-2020.
7.11 It is submitted that the Draft Westmeath County Development Plan 2021-2027, fully recognise the subject lands as unzoned lands located in a rural area and specifically in the defined Rural Areas under Strong Urban Influence, subject to the local needs policy for local family with direct ties to the land and local community.
8.0 PROPOSED URBAN DESIGN MASTER PLAN SOLUTION:
Of the subject Site under the Jurisdiction of the Westmeath CDP 2014-2020 and the draft Westmeath CDP 2021-2027, in a “Rural Areas Under Strong Urban Influence” subject to the Rural Development Policies and the undeveloped lands within the jurisdiction of the current and future Athlone Urban Development Plan and potential future Cornamagh Local Area Plan
8.1 It is proposed that the submitted Urban Design Master Plan attracted as Annexure be recognised and considered under the draft Westmeath County Development Plan 2021-2027 as for the merit of the urban design solutions that it presents for the subject site located in the statutory development area of “Rural Areas Under Strong Urban Influence” under the Westmeath CDP 2014-2020 and the draft Westmeath CDP 2021-2027 and the undeveloped lands within the jurisdiction of the current and future Athlone Urban Development Plan and potential future Cornamagh Local Area Plan located to the east and south east of the subject site, and also to the north and north west of the subject site.
8.2 The plan proposed an urban design solution and resolution of the Subject Site Located in a “Rural Areas Under Strong Urban Influence” zone, under the Westmeath CDP with the aspirations and proposed urban form under a future Athlone Urban Development Plan and potential future Cornamagh Local Area Plan in the following way.
8.3 It is considered that Proposed Urban Design Master Plan Resolution is a far more sustainable solution and resolved future vision for the general area. It provides for a more sustainable indictive road alignment further to the north and in line with the existing road to the west (locally referred to as the Bog Road). The master plan respects the existing land use rights of the subject site, under the Rural Areas under Strong Urban Influence owned by a local family with long established ties to the land and the local community that qualifies for rural housing under the rural housing policy, while presenting an integrated development solution to open space, adjacent future residential and community land zoning and land uses.
8.4 It is respectfully submitted that the Council seriously consider the principle and proposed solutions and recognises them and take account of them in the draft West Meath County Development Plan and its objective for a future Athlone Urban Plan, which in turn is likely to propose a future Cornamagh Local Area Plan.
28/06/20
To whom it may concern,
I am writing on behalf of the Longford Westmeath branch of the Green Party. We wish to make a submission for consideration during this final phase of producing the County Development plan for Westmeath. We would like to recognise the work put in by all involved in producing this extensive document.
With reference to the Core Strategy chapter of the document we would recommend:
With reference to the Housing chapter of the document we would recommend:
With reference to the Sustainable Communities chapter of the document we would recommend:
With reference to the Climate Action chapter of the document we would recommend:
With reference to the Landscape and Lake Amenities chapter of the document we would recommend:
If you have any questions or comments on these recommendations, please do not hesitate to contact the branch on 0872640589 or longfordwestmeath@greenparty.ie
Yours sincerely,
Aisling Connaughton
Secretary Longford Westmeath Green Party
Please see letter attached.
See attached submission
10.22 Renewable Energy Sources
Include additional bullet point, under the bullet point “The Government’s National Mitigation Plan, July 2017 (DCCAE).’ To read:
The Government’s National Energy and Climate Plan as submitted to the EU Commission under the Regulation on the Governance of the Energy Union and Climate Action (EU/2018/1999)
10.23.2 – Industrial Scale Wind Farms Pg.308
First paragraph, 2nd last sentence – replace ‘worked-out’ with ‘former’ industrial peatlands
Same Section: Wind Policy Objectives CPO 10.135
Removal of final bullet ‘carbon emission balance’ – Increase in overall carbon losses is a matter to be considered and is relevatn for all land types regardless of soil type.
It should be noted that these types of biomass products can be combusted in any boiler and for clarity we would suggest to amend to the following wording in paragraph 2 (Pg. 312) including the recommendation to amend CPO 10.146.
10.26 Bio-Energy
The 2nd sentence in paragraph 2 is not factually correct.
Replace with
10.27 Hydro
Recommend the inclusion of an additional CPO after CPO 10.146
"Support the development of an indigenous bioenergy sector, including the mobilisation of low value residual biomass for the production of renewable electricity."
Chapter 10 – Section 10.23 Wind Energy
The National Climate Action Plan (CAP) 2019 has set out an ambitious 70% target for renewable energy production out to 2030. To meet this target, the amount of electricity generated from renewables will have to be doubled on current figures. It is our view that the proposed Westmeath CDP must plan for and be supportive of all forms of renewable energy generation in order to contribute to this target and to Ireland’s transition to a competitive low carbon, economy by 2050.
Given the unique nature, character and scale of Bord na Móna's cutaway bogs we believe that the future use of these lands has the potential to make a significant contribution to national policies and objectives across a range of sectors including renewable energy, industrial development and job creation in rural areas, ecosystem services and biodiversity as well as tourism, amenity and recreation. In many cases these uses can be co-located thereby providing enhanced economic benefits to the areas in which such developments are located through direct and indirect employment opportunities. The optimisation and the realisation of the full potential value of the company's land bank is dependent on national, regional and local planning.
The suitability of peatlands for renewable energy developments in particular wind energy has been highlighted in the National Planning Framework (Project Ireland 2040) and in the Regional Spatial and Economic Strategy for the Eastern and Midland Region. In this regard, Bord na Móna warmly welcomes the inclusion of the following text in Section 10.23.2 of the Draft Plan on Industrial Scale Wind Farms:
“The Regional Economic and Spatial Strategy for the Eastern and Midland Region (RSES) refers specifically to the after use of peatlands and consideration of their potential contribution to climate change mitigation and adaptation including renewable energy production. With a strong history of energy production and an extensive electricity transmission network in place, the potential exists in such peatland areas for a smooth transition to renewable energy sources……The preferred locations for large scale energy production, in the form of windfarms, is onto cutover cutaway peatlands in the County, subject to nature conservation and habitat protection requirements being fully addressed.”
In addition, Bord na Móna welcomes, the many specific policy objectives listed in Section 10.23.2 addressing renewable energy, in particular the following:
CPO 10.135: Encourage large-scale energy production projects, in the form of Wind Farms, onto cutover cutaway peatlands in the County, subject to environmental, landscape, habitats and wildlife protection requirements being addressed.
These policy objectives point toward the significant potential for renewable energy development in County Westmeath. However, the inclusion of policy objective CPO 10.132, which specifies separation distances between wind turbines and residential dwellings is of significant concern, as it essentially prohibits the development of wind energy projects on Bord na Móna lands in the County and is in direct conflict with national and regional policy objectives to support the development of wind energy on peatlands and contribute to Ireland reaching its 2030 targets. It is also in conflict with the Wind Energy Development Guidelines 2006 and the Draft Revised Wind Energy Development Guidelines 2019 which state the following with respect to setback in Section 6.18.1:
“Taking account of the various factors outlined a setback distance for visual amenity purposes of 4 times the tip height should apply between a wind turbine and the nearest point of the curtilage of any residential property in the vicinity of the proposed development, subject to a mandatory minimum setback of 500 metres.”
The Guidelines go on to state that:
“It is a specific planning policy requirement of these Guidelines under Section 28(1C) of the Planning and Development Act 2000, as amended, that, in both their development planning and management functions, planning authorities shall not apply a setback distance that exceeds these requirements.”
Bord na Móna believe Westmeath County Council need to review and amend CPO 10.132 in light of this; not only to ensure consistency with the Guidelines, but also to ensure the Council’s wider commitment to support and enable renewable energy generation can be achieved.
Map 48: Wind Capacity
Bord na Móna also welcomes the commitment in Policy Objective CPO 10.149 to prepare a Renewable Energy Strategy for the County. In this regard, we would urge the Council to carry out a full assessment of renewable energy development in compliance with the methodologies outlined in SEAI Methodology for Local Authority Renewable Energy Strategies (LARES) and with the current Wind Energy Development Guidelines (2006) and the Draft Revised Guidelines (2019). This will ensure that a consistent and transparent renewable energy zoning methodology is in place for all developers.
On a similar note, we also request that in parallel with the development of a Renewable Energy Strategy, that the Council reviews the Landscape Character Assessment for the County to ensure a consistent approach to the determination of lands that are suitable for the development of wind energy projects in the County. Currently, as an example, the Bord na Móna Ballivor Bog Group (Westmeath portion) sits within the River Deel Lowlands landscape character area. While peatlands have been identified as being suitable for wind energy development, the River Deel Lowlands are designated as being of “Low” suitability for Wind Energy in Map 48: Wind Capacity, which is a contradictory situation. It is our view, that a review of the Landscape Character Assessment for Co. Westmeath in conjunction with the development of the Renewable Energy Strategy will result in greater clarity regarding the suitability of lands for wind energy development and will assist developers eliminate uncertainty at project inception stage.
Bord na Móna is now developing an accelerated decarbonisation programme. The company has also committed to a significantly larger rehabilitation target. This is reflected in our plans to rehabilitate a further 20,000 hectares of cutaway and cutover bog to wetland and woodland mosaics by 2025. In addition, we plan to restore a further 1,000 hectares of raised bog habitat by 2025 for example at Mostrim Bog (currently underway) and Glenlough Bog (proposed) in Co.Westmeath. These targets are significant in both timing and scale and are indicative of Bord na Móna’s increased new ambition in this area. This will deliver significant climate action and ecosystem service benefits. The development of naturally functioning peatland ecosystems will lead in time to the restoration of carbon sequestration potential. This will support the main carbon mitigation land-use objectives of the National Climate Action Plan, as reflected in the Westmeath County Development Plan, while also providing other benefits for biodiversity and other ecosystem services.
As can be seen from our Strategic Framework for the Future use of Peatlands, Climate Action is considered very important to the organisation and Bord na Móna can achieve these objectives in harmony on our cutaway and cutover peatlands with other commercial, industrial and employment generating land uses such as renewable energy, tourism and recreation.
Of the 17,000 ha of peatland in County Westmeath Bord na Móna own approximately one third; with much of this landholding connecting to larger peatland areas in neighboring counties. Much of our estate in Co. Westmeath comprises a mix of “cut-over” and “cut-away” bog which, with the accelerated cessation of peat extraction, present significant opportunities to achieve climate action and biodiversity objectives through appropriate rehabilitation and where possible restoration in conjunction with other commercial activities for example, the proposed Ballivor Wind Farm. Indeed, we have already restored several raised bog areas in County Westmeath and we are currently developing plans to accelerate and enhance our rehabilitation programme for the remaining areas using best practice restoration and rehabilitation methodology. This rehabilitation programme will support the main carbon mitigation land use objectives of the National Climate Action Plan while also providing other benefits for biodiversity and other ecosystem services.
Furthermore, we believe and indeed have demonstrated at our site in Mountlucas, Co Offaly, that it is possible to deliver on climate action and biodiversity objectives through peatland rehabilitation in perfect harmony with achieving other policy objectives and leveraging commercial opportunities, in particular, renewable energy generation and supporting indigenous, compatible new commercial opportunities. The former industrial peatlands at Mountlucas, for example, now supports an 84MW commercial wind farm surrounded by 1,100ha of rehabilitated peatland which has transformed this industrial landscape into a diverse mosaic of ecosystems from wetland to heathland to woodland. Mountlucas is also the site of the Company’s trial inshore aquaculture facility, the first of its kind, and also supports our emerging herb cultivation business.
With respect to CPO 12.58, “Exercise control of peat extraction, both individually and cumulatively, which would have significant impacts on the environment”, we would like to point out that all Bord na Móna’s historic peat extraction activities have been carried out under Integrated Pollution Control licences issued and monitored by the Environmental Protection Agency. As we transition from peat extraction and commence rehabilitation, we remain under the control of these licences which require us to stabilise the cut-over and cut-away peatlands through decommissioning and rehabilitation measures agreed with the Agency. In light of this we believe that CPO 12.58 ought to be amended to include the following text after “…control of peat extraction…”:
“…activities not otherwise controlled by the Environmental Protection Agency or pursuant to an environmental licence,…”
We welcome the principle of a regional approach to the planning for the future of the post-industrial peatlands across the Midlands as called out in CPO 12.60. As custodians of the country’s industrial peatlands we have over 30 years’ experience in the rehabilitation and, where possible, the restoration of these landscapes. We have also identified appropriate alternative sustainable future uses which we have successfully integrated with this rehabilitation process as demonstrated at Mountlucas, Lough Boora and Oweninny for example. In 2011 the company published its “Strategic Framework for the Future Use of Peatlands” identifying the challenges and opportunities associated with the re-purposing of industrial peatlands; and outlining the factors which should be considered in developing a future use strategy for these peatlands. With the accelerated decarbonisation of our business operations in recent years and especially in the last 12 months we have reviewed and updated this framework with the revised edition due to be published in the coming weeks: “Bealach Úr, Bealach Glas - The Future use of our Peatlands”. We believe that this plan should be acknowledged and specifically called out in CPO 12.60. CPO 12.61 in calling for a collaborative approach in the development of an integrated peatland management plan echoes similar objectives at CPO 10.138 and CPO 11.6. We consider future sustainable peatland management inherently linked with the future land use strategy. We believe and indeed we have demonstrated at Mount Lucas, Oweninny and Lough Boora that our peatlands can be re-purposed to harmoniously deliver in the areas of renewable energy, recreation and amenity, climate mitigation and biodiversity. In the context of developing such a peatland management plan we suggest that our strategic plan, “The Future use of our Peatlands” should inform its development.
For the avoidance of potential inconsistencies, we suggest that only one of the three CPO’s referred to in the previous paragraph should be retained in the final plan or if they are each to remain, they ought to be drafted in identical terms. Similarly, we suggest that the objectives of CPO 12.63 is encapsulated in CPO 12.61 and ought therefore to be removed from the final plan to avoid potential ambiguity.
See submission attached
SUBMISSION IN RELATION TO THE WESTMEATH DRAFT COUNTY DEVELOPMENT PLAN 2021-2027
Dara Reid
29th June 2020
To Whom it concerns,
I wish make a submission in relation to the proposed County Development Plan 2021 – 2027 and to raise concerns over the downgrading of all policies in chapter 13 for the landscape, lakes and areas of high amenity for the entire county from policies to policy objectives.
SECTION 13 of the proposed plan: Landscape and Lake Amenities Policy Objectives
In downgrading all policies to policy objectives the protections due to our landscape, lakes and areas of high amenity have been undermined & weakened leaving them open to challenge & inappropriate development.
A policy is a statement that is implemented and followed as a procedure or the protocol whereas policy objectives are desired outcomes.
The current County Development Plan 2014-2020 clearly defines between policies & policy objectives therefore, so as to avoid any confusion policies should remain policies in the proposed 2021 – 2027 County Development Plan.
Yours sincerely,
Dara Reid
Please see attached pdf letter in consideration of this submission
The draft plan mentions little about the Royal Canal in terms of tourism, emphasis is firmly on Greenways, Blueways and Peatways. The canal navigation offers great tourism potential, not just seasonally but year-round.
Hello
I would be including this in the Development plan as i feel the effects from microplastics on our aquatic enviroment is not currently monitored in any reasonable way.
The effects of plastics on our enviroment is not properly monitored and i feel this is having a negitive effect on our all of our lives and wildlife that yet to be properly understood. I propose to start monitoring levels of microplastics in all water treatment plants, and a select number of lakes and rivers in the Westmeath Area.
This could be a pilot scheme and could lead to appropiate action based on results and findings of the monitoring period.
We are seeking that the council provide for expansion work to be completed on the R392 regional road to cater for:
1. Increase the safety for use of this important tourist road by cyclists,
2. Improved road traffic safety measures along specific sections of the route and
3. Wider carriageways for increased volumes of public transport services along the route
Re: Draft County Development Plan 2020.
Dear Sir/Madam,
I have reviewed the recent Draft of the County Development Plan (hereinafter called "the draft") and wish to make the following comments and suggestions, which I have placed in sequential order for your ease of reference:
- 1. Uisneach:
While I note that Uisneach has now been listed as an archaeological setting with specific zones of protection in the draft, I note that these zones are limited to the circumference of the hill itself. These zones do not extend beyond the hill to the panoramic views from the summit of the hill, which are an intrinsic part of the value of this setting.
Similarly, I also note that the draft refers to the placement of Uisneach on the U.N.E.S.C.O tentative list however the draft fails to afford the setting any of the protections which this setting of both national and international renown would require, in advance of this nomination process.
I also note that the Uisneach landscape policies contained in our current Plan are now re-listed as policy objectives. This appears to be an unnecessary adjustment to the clearly defined policies in our current Development Plan.
On this basis, I am now seeking that the current policies for Uisneach, which are now listed as policy objective numbers 13.17 and 13.18 are reaffirmed as policies.
Furthermore, I am also seeking the insertion of a policy to ensure the sensitivity of this historic setting is maintained, namely that the precautionary principle is applied prior to the grant of any permissions:
Suggested Additional New Policy for Uisneach:
“As a landscape of both national and international renown, it is a policy of Westmeath County Council to apply the precautionary principle and ensure that the setting of the Hill of Uisneach and its associated zones are maintained and enhanced in advance of any formal nomination and or preparation of a management plan. In advance of any formal grant of planning permission, Westmeath Co Council will apply the zone of theoretical visibility including reverse zones as defined in the International U.N.E.S.C.O Guidelines, to define where development would not normally be permitted due to the sensitivity of the setting and its associated zones; Development will be subject to scrutiny in terms of its impact on the setting of the Hill of Uisneach.”
2. Industrial Scale Wind Farms and associated Wind Energy Maps:
I note that the western lowlands, namely area 7 is being rezoned as a landscape area which may have capacity for wind energy as opposed to other areas within Westmeath. I note there is no justification or explanation for this re-zoning within the draft plan. This rezoning is a contradiction of Policy P-Win 2 in our current Development Plan which strictly directs Industrial Scale Windfarms to areas of cut away bog land.
Also, I must question why the new wind energy policy, which is now called policy objective 10.135 in the draft, dilutes the original terms of P-Win 2, which strictly directs industrial windfarms to cut away bogs.
I note that policy objective 10.135 indicates that the council will "encourage" rather than "shall strictly direct" industrial scale windfarms to cut away bogs.
I also note that the criteria to determine industrial scale windfarms in policy objective 10.135 is also ambiguous. It omits the word "or" from the three alternative criteria which identify industrial windfarms.
In this regard, I do not accept that area 7 should be rezoned on the wind energy maps and I am also seeking the full re-instatement of Wind Energy Policy P- Win 2 from the current Development Plan without amendment.
3. Noise Pollution:
I note that policy objective 10.123 in the draft requires all development to be designed and operated in a manner that will minimise and contain noise levels in accordance with Noise regulations. I would suggest that the actual noise regulations should be defined to avoid any ambiguity in the plan.
In this regard, I would suggest the following additional wording for 10.123 as a policy which
Requires all development to be designed and operated in a manner that will minimise and contain noise levels in accordance with World Health Organisation's 2018 Environmental Noise Guidelines (as may subsequently be amended).
I would also question the ambiguity in policy objective 10.136 that the council should ensure that proposals for either energy development demonstrate that human health has been considered, including those relating to the topics of:
(a) Noise (including consistency with the World Health Organisation’s 2018 Environmental Noise Guidelines for the European Region)
It is not an adequate policy objective to simply "consider" issues of human health.
Policy 10.123 should require all energy developers or transmitters to comply with W.H.O Guidelines. Health protection should be a policy requirement which underpins all schemes for energy development/transmission.
I would also suggest the following new wording for 10.136 (a) as follows:
It is a strict policy of Westmeath County Council that all proposals for energy development and or transmission comply with World Health Organisation Guidelines including those relating to the topics of:
(a) Noise (including consistency with the World Health Organisation’s 2018 Environmental Noise Guidelines for the European Region) and are managed and assessed by the energy developer on an ongoing basis by the developer using B.A.T (Best Available Technology as defined by Section 5 in the EPA Act 1992) in accordance with the W.H.O Guidelines and Environmental Noise Directive 2002/49/EC.
5:Set Back Distances:
5. I note that 10.132 recommends set back distances for "wind turbine generators" according to specific heights. However, the heights aren't adequately defined. Considering the scale and height of both the turbines and their blades, this height should be described according to the height of the wind turbine generator including the height of their blade.
Landscape, Lakes and Areas of High Amenity:
6. I must question the proposed amendments of the existing policies for the lakes in the current Development Plan to policy objectives in the draft, considering the national renown of Westmeath as the "Lake County". The differing lakes form an essential mosaic of areas of high amenity value throughout the county, from Lough Ree in the west to Lough Derreveragh in the North and Loughs Owel and Ennell in the heart of the County.
These policies for the lakes are essential to protect these unique landscape resources. Their associated high amenity status is also intrinsic to the human enjoyment of these natural resources within the county. Our current Development Plan provides a clear distinction between the differing policies and objectives for the lakes. I do not accept any justification for amending or altering the status of these policies in the draft Plan.
In essence, I do not accept there is any justification for the amendment of all the landscape policies and amenity policies in Chapter 13 of the draft Plan.
I also note that proposed policy objective 13.11 requires a visual impact assessment for proposed developments with the potential to impact on significant landscape features within the county.
I would submit that a visual impact assessment is a superficial assessment of development, a more rigorous landscape assessment should be utilised in accordance with national guidelines.
I would suggest the following change to policy objective 13.11:
It is a policy of Westmeath County Council to require landscape and visual impact assessment for significant developments within the County and or developments with the potential to impact on significant landscape features within the county.
Furthermore, I note that the relevant assessment guidelines are also omitted in the proposed draft. The guidelines which underpin such assessments should be in accordance with the standards which are typically applied by An Bord Pleanla.
Suggested New Additional Policy: "The undertaking of landscape and visual impact assessments should be carried out in line with the Guidelines for Landscape and Visual Impact Assessment, 3rd Edition, 2013 issued by the Landscape Institute and Institute of Environmental Management and Assessment (IEMA) and any superceeding guidelines which the IEMA may issue. The Landscape and Visual impact assessment should address all elements of the proposed development including related infrastructure."
In summary, we are seeking the re-instatement of all the aforementioned policies in the current Development Plan together with an improvement on the existing policies for both Uisneach, the lakes, the landscape and health protection particularly in relation to the areas of either energy development or transmission.
Yours sincerely,
Cllr Denis Leonard
Cllr Johnny Penrose
Please see attached document.
30th June 2020
Draft Westmeath County Development Plan 2021 - 2027
Senior Executive Officer
Planning Department
Westmeath County Council
Aras An Chontae
Mount Street
Mullingar
N91 FH4N
Submitted via the online consultation portal
Our Ref: 501-00180-00141-20RL
Your Ref: Draft Westmeath County Development Plan 2021-2027
Dear Sir/Madam
RE: DRAFT WESTMEATH COUNTY DEVELOPMENT PLAN 2021-2027
SLR Consulting Ireland acts as planning and environmental advisors to Roadstone Limited, Fortunestown, Tallaght, Dublin 24 and Derryarkin Sand and Gravel Ltd., Bord Na Mona Offices,
Main Street, Newbridge, Co. Kildare. This submission relating to the Draft Westmeath County Development Plan 2021 – 2027 has been prepared on their behalf.
ROADSTONE lIMITED
Roadstone Ltd. was formed in 2009 by the amalgamation of three of the construction materials businesses operated by CRH in Ireland, which were Roadstone Dublin Ltd., Roadstone Provinces Ltd. and John A. Wood Ltd.
The company is Ireland’s leading supplier of aggregates, construction and road building materials and it employs several hundred people throughout the country.
Roadstone forms part of CRH, which is an international building materials group. It was founded in the 1930s and became part of Cement Roadstone Holdings (CRH) plc in 1970, following the merger of Roadstone and Cement Ltd. CRH is the leading global diversified building materials business in the world, employing 79,200 people in 30 Countries across the globe.
Derryarkin Sand & Gravel ltd.
Derryarkin Sand and Gravel Ltd. is a joint venture company between Bord na Mόna and Roadstone Ltd. It currently operates a sand and gravel pit on a site which straddles the county boundary between Offaly and Westmeath.
Property Assets
Roadstone Ltd and Derryarkin Sand and Gravel Ltd. have property assets / extraction locations within the Westmeath County Council administrative area, refer to Figure 1 which shows the sites at:
These property assets / extraction locations contain aggregate resources and they are essential to the future long-term secure supply of aggregates to support the local, regional and national economy.
Figure 1 Roadstone and Derryarkin Sand and Gravel Sites in County Westmeath
Basis of the submission
National and Regional Policy Context
The importance of the extractive industries to the wider economy and the need to protect the operations of working quarries, sand pits and proven aggregate resources is firmly established in national and regional planning policy.
Project Ireland 2040, the National Planning Framework refers to the following National Policy Objective which is supportive of the extractive economy. National Policy Objective 23 states that it is the intention of the NPF to (emphasis added):
‘Facilitate the development of the rural economy through supporting a sustainable and economically efficient agricultural and food sector, together with forestry, fishing and aquaculture, energy and extractive industries, the bio-economy and diversification into alternative on-farm and off-farm activities, while at the same time noting the importance of maintaining and protecting the natural landscape and built heritage which are vital to rural tourism.’
Regional Spatial and Economic Strategy 2019-2031 for the Eastern and Midland Regional Assembly also acknowledges the role of the extractive industry and ‘recognises that the rejuvenation of rural towns and villages requires that appropriate job creation in rural areas and that traditional sectors such as agriculture, tourism, extractive industries and forestry are complemented by diversification in sectors such as food, renewable energy and opportunities provided from improved digital connectivity’.
The RSES acknowledges that minerals form part of the region’s natural capital, and presents regional policy objective 6.7 in support of the extractive industry in relation to economy and employment (emphasis added):
RPO 6.7: Support local authorities to develop sustainable and economically efficient rural economies through initiatives to enhance sectors such as agricultural and food, forestry, fishing and aquaculture, energy and extractive industries, the bioeconomy, tourism, and diversification into alternative on-farm and off-farm activities, while at the same time noting the importance of maintaining and protecting the natural landscape and built heritage.
The Importance of the Extractive Industries
In preparing policies that reflect the importance of the extractive industries, the planning authority should consider the recently published Essential Aggregates – Providing for Ireland’s Needs to 2040[1] prepared by the Irish Concrete Federation (refer to copy appended to this submission).
The objective of this document is to highlight to Government the need for a national planning policy for aggregates, which will underpin local and regional planning policy and ensure the sustainable supply of aggregates for Project Ireland 2040 and beyond. The document provides further detail on the role of locally supplied aggregates in supporting the demand for new homes, new schools and better infrastructure. In meeting the demand arising from the projected population increase of an additional 1 million people as identified in the National Planning Framework, it is worth noting that every new home typically requires up to 400 tonnes of aggregates and every new school typically requires some 3,000 tonnes of aggregates. These requirements are most sustainably met by local sources and suppliers.
The document also makes recommendations to ensure that Government’s stated objectives on aggregates within the National Planning Framework 2018 are implemented, not just for the benefit of the extractive industry, but also for the achievement of the ambitious goals of Project Ireland 2040. It highlights three important points that statutory planning policy needs to address at all spatial scales. These are:
DRAFT WESTMEATH COUNTY DEVELOPMENT PLAN POLICIES
The draft Westmeath County Development Plan 2021-2027 addresses a range of matters that are relevant to extractive industries and includes a number of relevant policies within Chapter 9 Rural Westmeath and Chapter 16 Development Management standards.
However, it is noted that in Chapter 5 Economic Development and Employment there is no mention of the quarry or extractive industry, its potential or any objectives assigned in the same regard. This is in contrast to the current County Development Plan and its comparator chapter 3 Economic Development, which acknowledges the value provided by the extractive industry and demonstrates an understanding of the natural underlying conditions that should be taken into account, in order to facilitate the successful use of aggregates. A number of policies and objectives are provided in the existing plan, demonstrative of the same.
The proposed Chapter 9 Rural Westmeath, on the other hand, acknowledges the County contains a variety of natural resources such as raw materials critical to the construction industry in the form of sand, gravel, stone reserves including high purity limestones and shale and base metal deposits. The potential of these resources to underpin construction output and provide employment and economic growth in the local and regional economy is recognised as is the need to exploit such resources in an environmentally sound and sustainable manner.
However, it is further stated that given the quantity of existing quarries in the county, the Council considers that there are already sufficient aggregate deposits available without requiring new or extended extraction pits in esker systems or any new quarries on greenfield lands. It is the policy of the Council to take cognisance of existing levels of extraction in considering new applications for development on greenfield sites and preference will be given to the sustainable continuation or extension of existing quarries. With this in mind, the following extractive industry policy objectives have been proposed:
CPO 9.58
Ensure that development for aggregate extraction, processing and associated concrete production does not significantly impact the following:
CPO 9.59
Facilitate adequate supplies of aggregate resources to meet the future growth needs of the County and the wider region where there is a proven need for a certain mineral/aggregate and to exercise appropriate control (including ongoing consideration of environmental impacts) while addressing key environmental, traffic and social impacts and details of rehabilitation.
CPO 9.60
Facilitate the exploitation of the County’s natural resources and to exercise appropriate control over the types of development, including rural housing, taking place in areas containing proven deposits, whilst also ensuring that such developments are carried out in a manner which would not unduly impinge on the visual amenity or environmental quality in the area.
CPO 9.61
Ensure that extractions (quarries / sand and gravel pits) which would result in a reduction of the visual amenity of areas of high amenity or damage to designated sites, habitat types or species shall not be permitted.
CPO 9.62
Ensure that extractive developments do not adversely impact on environmental quality, including water quality, tourism value, existing infrastructure, residential amenity or the amenity value of neighbouring lands.
CPO 9.63
Ensure that all extractions shall be subjected to landscaping requirements and that worked out quarries should be rehabilitated to a use agreed with the Planning Authority which could include recreational, biodiversity, amenity or other end-of-life uses. The use of these rehabilitated sites shall be limited to inert waste and sites shall be authorised under the appropriate waste regulations.
CPO 9.64
Ensure that the extractive industry and associated development minimises adverse impacts on the road network in the area and that the full cost of road improvements, including during operations and at time of closure, which are necessary to facilitate those industries are borne by the industry itself.
Chapter 16 Development Management Standards presents a section dedicated to the extraction industry titled ‘Extractive Industry (Quarries/Sand and Gravel Pits)’. It states that planning applications for any extractive industry should have regard to the Quarrying and Ancillary Activities (DEHLG 2004), Guidelines for Environmental Management in the Extractive Sector (EPA, 2006), Guidance on Biodiversity in the Extractive Industry (NPWS), GSI’s Geological Heritage Guidelines for the Extractive Industry, the Archaeological Code of Practice and the Irish Concrete Federation Environmental Code (2005) and any other relevant superseding policy guidance. In addition, the following development management objectives are set with respect to any lodged planning applications relating to the extractive industry:
CPO 16.53
Details which should be submitted by the applicant as part of proposal:
These should include a report with plans and section drawings, detailing the following:
CPO 16.54
Require by way of planning condition that the developer lodge a financial bond to ensure the satisfactory reinstatement of the site following the completion of extraction. This bond shall be index linked.
CPO 16.55
A special contribution levy may be required from the developer towards the cost of upgrading or repairing the local roads serving the quarry and to minimise the adverse impacts of associated quarry operations on the road network.
SUBMISSION COMMENTS
The following outlines the key points that Roadstone Ltd. and Derryarkin Sand and Gravel Ltd. would like to address in relation to the proposed Draft Westmeath County Development Plan 2021 – 2027.
In contrast to the current County Development Plan and its comparator chapter 3 Economic Development, there is no mention of the quarry or extractive industry within the proposed Economic Development and Employment chapter, other than to highlight a decrease in those employed in mining and quarrying from 153 (2011 Census) to 130 (2016 Census).
It is therefore submitted that the plan is revised to adequately outline the economic value and significance of the aggregates sector, similar to how the existing county plan does so, emphasising the sectors significance in terms of economic development and employment. In addition, the noted decrease in sector employment numbers, as described, should be cause for alarm and adequate mitigation measures and methods that facilitate a restoration of employment levels should be proposed. The importance of the sector should be stressed within the proposed plan and its significance with regard to construction and development supply chains, as well as the county’s growth objectives should be made clear. A successful quarry and extractive industry within the county is to the benefit of numerous stakeholders involved in the development of residential buildings, infrastructure, health care facilities, education facilities and all other forms of built development.
Extraction can only take place where resources occur and it is, therefore, tied to certain locations. It should be ensured that the County Development Plan allows for the provision of adequate aggregate resources to meet the future growth needs of the county and to facilitate the exploitation of such resources where there is a proven need for a certain mineral/aggregate.
This of course, should be facilitated, whilst exercising appropriate control over the types of development taking place in areas containing proven deposits and should be subject to the necessary environmental assessments. Furthermore, there is a need to safeguard valuable un-worked deposits from permanent development that would prevent or hinder their future extraction.
These considerations will allow the aggregates sector to continue to facilitate its crucial role within construction and development supply chains, therefore supporting economic development and employment in the county and further afield.
The extractive industry related policy objectives as included in Chapter 9 Rural Westmeath are welcomed. It is considered that the inclusion of the proposed policies is a positive and demonstrate an acknowledgment of the economic importance of the industry. It is submitted that the Council should have due regard to Roadstone Ltd.’s and Derryarkin Sand and Gravel Ltd.’s property assets within the county and the added value these bring in terms of the local, regional and national economy. It should be noted that these property asset / extraction locations are long established, providing significant socio-economic benefits to the area.
Nonetheless, the proposed plan states “that given the quantity of existing quarries in the county, the Council considers that there are already sufficient aggregate deposits available without requiring new or extended extraction pits in esker systems or any new quarries on greenfield lands”.
There is no basis or evidence provided by Westmeath County Council to support the above statement. The number of existing quarries alone is not a robust basis for determining available aggregate resources and reserves. A detailed assessment of the resource and reserves associated with each of the individual quarries, together with an assessment of future demand in the marketplace would be required before any such conclusion could be made. In the absence of such an assessment it is recommended that this statement be removed from the final CDP document.
The policy objectives and related development controls proposed in the new plan within Chapter 16 Development Management Standards are generally considered reasonable for the sector and should be emphasised that Roadstone Ltd.’s and Derryarkin Sand and Gravel Ltd.’s property asset / extraction locations are in accordance with the proposed development controls.
Nonetheless, it should be noted that there exists an abundance of sand and gravel reserves in Co. Westmeath, and their potential for regulated extraction in support of the county’s growth objectives should not be disregarded.
Durations of Planning Permissions
In addition, in relation to CPO 16.53 and the reference made to “limited durations on permissions”, the Council should be made aware of the necessary sizeable costs involved in the initial development of any quarry operation and that such operations could not be sustained or made viable should only a short duration permission be implemented. The durations of planning permissions should factor in the life of the proven reserves within the development and the policy wording should be revised to incorporate same.
Special Contributions
Policy CPO 16.55 refers to special contributions and stated that “A special contribution levy may be required from the developer towards the cost of upgrading or repairing the local roads serving the quarry and to minimise the adverse impacts of associated quarry operations on the road network.” It should be acknowledged that the sector provides significant financial contributions to local authorities through the Development Contribution Schemes and payment of rates (for example, the current Westmeath County Council Development Contribution Scheme 2013-2020, Table 2–E levies €6820.00 per hectare on extractive developments). If applied, any special contribution on a particular development should be determined on a proportionate basis in the context of overall traffic usage and traffic related to the development.
It should be noted that aggregate resources are not evenly distributed across the Country or County and can only be worked where they occur naturally. As well as providing essential building materials for the construction industry, they are also essentially a finite resource – once extracted they will not be replaced. While Roadstone Ltd. and Derryarkin Sand and Gravel Ltd. are broadly in favour of the policies and objectives outlined above, it should be highlighted that there is further potential to strengthen policy provisions in relation to identifying and protecting aggregate reserves in the County.
Under other planning systems (including England and Wales), this is standard practice and is referred to as the ‘safeguarding of reserves’. Guidance on the planning for mineral (aggregates) extraction in plan making and the application process[2] defines the purpose of safeguarding as follows:
Since minerals are a non-renewable resource, minerals safeguarding is the process of ensuring that non-minerals development does not needlessly prevent the future extraction of mineral resources, of local and national importance.
This guidance also states that the relevant planning authorities should adopt a systematic approach for safeguarding mineral resources, which include the following principles:
In accordance with the above approach, Roadstone Ltd. and Derryarkin Sand and Gravel Ltd. would suggest that under CPO 9.60 areas containing proven deposits are shown on a map in order to protect them from the future development of incompatible land use.
The adopted County Development Plan should ensure that the extraction of aggregates can take place in suitable locations where the resource exists. It is important to ensure that the future interpretation of County Development Plan policies does not result in the sterilisation of aggregate and related resources and does not prevent the secure, long-term supply of construction aggregates, and value-added products such as concrete products and road making materials.
Yours sincerely
SLR Consulting Ireland
Aislinn O’Brien
Principal
Enc. Copy of “Essential Aggregates” (Irish Concrete Federation, 2019)
Cc. Mr. S. Geraghty (Roadstone Ltd.)
[1] https://www.irishconcrete.ie/wp-content/uploads/2019/10/Essential-Aggregates-Final.pdf
[2] https://www.gov.uk/guidance/minerals#minerals-safeguarding
Please see attachments
That the County Development Plan includes an objective in relation to identifying possible uses of those marginal lands in ownership of the Council which may be identified as suitable for community gain/bio -diversity or related use.
Kinnegad Action Group and Kinnegad Community Council
County Development Plan Review
June 2020
Denis Leonard Jimmy O’Connell
Chair Chair
Kinnegad Action Group Kinnegad Community Council
We would like to state at the outset that a lot of work went into the Kinnegad Action Plan launched in 2019 in conjunction with the Community Development section of Westmeath County Council and we would like this plan to facilitate as much of that roadmap as possible. This is particularly in the areas of Community development, infrastructure, sporting, recreational and community facilities, enterprise, tourism, streetscape and local transport options.
We also agree with and have pushed in the past for the following points on future development that were presented by our local councillor Denis Leonard in his February submission to this plan.
The following general points have been made by this body going back to 2003 and by our local Cllr Denis Leonard. Can these general areas be taken into account to in the new 2021-27 plan:
Conclusion
Our natural environment is being constantly threatened by developments done in the name of progress. Hedgerow removal must be a major concern throughout the county as the agricultural sector continues to expand field size to facilitate the expansion of the Dairy Herd.
More alarming is the proposal to make changes to some of the high amenity areas in the county and to rezone lands in the hinterland of our lake shores particularly Lough Derravaragh and Lough Lane. On behalf of our Ethos Group in Tyrrellspass I strongly object to any such changes without prior consultation with the public. The decision to rezone must be done after consultation with experts who understand the delicacy and fragility of the biodiversity in these protected areas.
Sincerely, Eugene Dunbar (Secretary Ethos Tyrrellspass)
Our Client (the Parish) has been, at the very least, philanthropic to date in its role as community stakeholder/supporter, in providing lands to facilitate vital community infrastructure and services for the consolidation of the Village and to promote the objectives of logical and orderly planning and development. The area of lands provided for these uses amounts to in excess of approximately 6 acres.
In this regard and for the benefit of the best use of urban lands and the consolidation of the lower end of the Village of (Killucan) Rathwire which has experienced disproportionate residential growth in one respect to the overall village area it is presented that Westmeath County Council respectfully zone the remaining parish lands as can allow for a mix of potential uses in the locality as might provide for further schools expansion, additional infrastructural supports to the existing wastewater treatment plant and complementary vIllage consolidation uses as might suggest Community/Residential/Mixed Uses to allow for a greater sense of community and or ‘placemaking’.
The zoning of these lands for ‘consolidation’ and ‘community, educational & institutional’ would facilitate the viable development of the zoned lands complementary to developments to date. Due to the location of these lands adjacent to the school, it is undeniable that they offer the opportunity to enhance this area of the settlement and to improve connectivity with surrounding uses. The portion of the landholding to the south of St Joseph’s School could then be reserved for the future expansion of the Waste Water Treatment Plant.
Visible Bus Stops in villages and along routes where bus routes link rural hinterlands to their market town/village
Space for Buses to pull in
Bus stops throughout towns
Bus shelters in towns and along routes
Public transport is an important function and access to public transport includes safe places to wait and safe areas to get on and off buses.
See attached maps with area hatched out on same
Zoning of Land in Multyfarnham - see interactive map
Clonmellon's thoroughfare is part of the National Secondary Route, the N52. There is high volume of traffic, including HGVs coming through the village in both directions daily. The route links to M3 (Dublin, onwards to M1 Belfast) to the north as well as the N4/M4/M6 to the south.
Issues:
Speeding in the village: The speed limit through the village is 50 km, which comes into effect right at the town boundary at all entrance points. However both entry points along the N52 are on bends- with a 90 degree bend on the Mullingar side. Sight lines at the KElls end are obscured. Quite often traffic, including HGVs do not slow down and obey the speed limit coming through the village.
School Entrance: the school entrance is just past the brow of a hill, and is obscured coming from the Mullingar side. Flashing amber lights and school caution signs are in place, but are located far too close to the school entrance, thus not giving vehicles sufficient notice of the potential dangers of children entering and exiting the school. In relation to parental drop offs, there can be erratic behavior during drop off and collection times, as there is insufficient parking along what is a very busy national road. At times parents have to reverse out of the drop off area as parked cars block their way. This increases the potential danger to children and road users.
Pedestrian Crossing. Additionally the pedestrian crossing (signal controlled) is at the brow of the hill; however the majority of parents and children cross the road directly outside the school. There have been several near misses over the years when traffic have been speeding and children crossing the road. We would like you to consider putting an additional crossing outside the school. The church and shop are located here too so it would make sense to locate it here.
Bus Parking There is two bus parking spots adjacent to the school (parallel to the side of the school). The bus drivers park there for the after school pick up however it is too dangerous for them to park there in the morning as they have to reverse over a busy footpath. Even in the evening time there have been times children have run in front of the buses because the bus has to pass a busy footpath. Currently the buses park in front of the school for the morning drop off however this area is not marked for a bus drop off. It is in front of the set down area and again people walk in front of the bus. It is dangerous. If a car is already parked there they have to wait for it to move which holds up traffic on a busy road. Sometimes this leads to traffic overtaking the bus which can be very dangerous. We would like you to consider allocating a dedicated school bus stop which is clearly marked. The set down area in front of the school is not large enough for a bus to turn.
Signage & road markings: There is insufficient signage announcing the town in advance on both N52 approaches, thus reducing the ability to attract passing traffic. As mentioned above, speed limit signage needs to be improved on all entrances to the villages, for safety reasons.
'Caution, school ahead' road markings on both N52 approaches would be welcomed as a traffic calming measure.
The drop off area at the school needs to be relined (entry and exit). Bus parking could be located outside the church or credit union.
Traffic Calming measures: to respond to the above, we welcome the consideration of the installation of traffic calming measures, as appropriate. Clonmellon has a very wide main street and traffic often speed up or overtake on the road. The children of Clonmellon National School took part in a Love 30 minute walk through the village last year, to promote slower traffic in the town. We would also suggest reducing the speed limit from 50km/h to 30km/h through the village as well as more policing of adherence to limit.
We feel that the safety issues raised will have an impact on some of the actions outlined in the settlement plan particularly CPO 8.215- development of an amenity park, located right at the obscured bend at the Kells end of the N52 (see map extract below). There will be a large number of children and families using this park once completed, and we fear that, due to the location of this park, safe access and egress from it will be impacted if road safety measures are not taken.
please add and prioritise an objective to undertake a traffic management and road safety review. Road safety issues near the school is of key importance. factors to review include:
- Parking and traffic management in Clonmellon
- Review of safety issues with cars and school buses at lay-by are outside school
- safety assessment of the approach road design including carriageway reduction and traffic calming measures
- speed limit review on approach roads and through village centre
- Pedestrian Crossing at/near school
- review of directional/road signage and road markings
Road Safety, Concern of fatal accident/children of pedestrians being struck by passing traffic
Clonmellon is the gateway to North Westmeath is located on key transport route. It has close proximity to the Boyne Valley tourism area.
We have a great heritage and architectural traditions. Killua Castle is undergoing extensive development and it is a great tourism attraction. It has significant links to Lawrence of Arabia. A Country market has been established, with its first outing on 5th July 2020- this has attracted considerable interest from producers form Westmeath, Meath, Cavan and beyond
St John's Church (part of the Killua Castle estate) is located in the center of Clonmellon and has been restored to a high specification. It has been used effectively as a concert / recital venue in several occasions as well as by the community as a community space. There has been an increase in the number of tourism accommodation providers in Clonmellon and its hinterland- this includes, self catering, B&B, Glamping and Air B&B offerings.
The Market Square has fantastic potential for development and could be a thriving hub of tourism in our village, as well for the wider North Westmeath area. With its favourable location, close to the M3 ( to Dublin, M1 Belfast), N3 (Cavan and northwest), Clonmellon (Market Square or main street vacant building)would be a perfect location for a local tourist office- to promote all that north Westmeath and beyond has to offer (Killua Castle; Fore; Lough Lene; Tullynally Castle; Mullaghameen Forest; Belvedere, Athlone etc).
The development of a heritage trail and cycling/walking trails is welcome, but Clonmellon is very much out of the narrative in respect of North Westmeath Tourism, and tourism development.
Action CPO 8.10 (Castlepollard settlement plan) is to support the development of a collaborative marketing plan to define the North Westmeath Tourism Cluster concept, in line with Ireland's Ancient east brand and Westmeath County Council Tourism Strategy.
Clonmellon should be clearly associated and linked into this plan and the North Westmeath Tourism Cluster Concept.
There is opportunity to leverage some of the visitors to the Boyne Valley area, through Clonmellon’s proximity to it, and the connections already developed with Kells Hinterland Festival, Causey Farm and Boyne Valley Flavours network.
Clonmellon is the gateway to Westmeath, but often, as we are on the fringes we are forgotten. We want to fully embrace our Westmeath identity and be a part of its tourism development plans. Over the period of this County Development Plan, Clonmellon could become a thriving tourism hub. Please bring Clonmellon into the plans for North Westmeath tourism.
Associate Clonmellon with Action CPO 8.10 (North Westmeath Tourism Cluster Concept)
Support the development of the tourism identity in Clonmellon (Walter Raleigh, Lawrence of Arabia, architectural heritage, walks/trails and cycling, country market)
Develop Clonmellon as a destination for bespoke events ( Market Square/St John Church/mini festival/concerts/recitals/Potato Festival/Country Market)
Support the development of tourism amenities and businesses in Clonmellon
Support the development of a tourist office/hub in Clonmellon, as it is the Gateway to North Westmeath
Economic Development,
To expand the North Westmeath Tourism area
To build Clonmellons sense of place and identity as part of Westmeath
Please see attached.
Seeking to extend residential zoning by 0.8 acres
1.7 acres of land suitable for residential Zoning in Clonmellon Co. Westemath.
All services are available on the site.
See map attached.
Please see attached
Please see attached submission prepared by MKO on behalf of Supermacs (Ireland) Ltd.
This submission has been prepared by MKO and relates to the proposed zoning of the subject lands in Kinnegad, Westmeath, along with the proposed new link road outlined in CPO 8.103. This submission also outlines recommended changes to the Land Use Zoning Matrix, which woud be more inclusive of development types within certain zonings.
North Westmeath, already has the historic site of Fore Abbey, its Seven Wonders of Fore and the gardens of nearby Tullynally Castle. This area of the county is particularly pretty with picturesque country scenes and easy access to lakes. But our Lakes are just big holding ponds of water, so much more could be done to utilise their beauty, fishing and inland family resources like a Lido which could be properly managed and controlled. At present Lough Lene, Owel and Derrvaragh are undermanaged and not visited by the tourist the latter of which is associated with the famous Irish legend The Children of Lir could be a major attraction to the north midlands. New and exciting walking cycling tracks could be developed along the bed of the old Cavan railway line with easy access all along its route from Multyfarnham to Ballywilliam just outside Granard and possibly further away to Co Fermanagh. The Majestic River Inny is another natural blue-way crying out for development stretching from Finnea to Lough Ree passing mostly through Westmeath and past the new Centre Parcs in Ballymahon. Streete is also an area of great historic significance with Deramona house and its early scientific discoveries waiting to be rediscovered. The list of endless possibilities is here waiting to be developed. We welcome the council's views as to how we can work together on developing a future plan for these golden opportunities.
Please find attached WECAN submission on the draft CPD 2021- 2027 organised by Section of the CPD. Feel free to contact us for clarification of any aspect of this submission.
The North Westmeath Turbine Action Group are a community based voluntary group opposed to the destruction of north Westmeath through the imposition of large scale industrial wind turbines on the bogs of Coole, Doon, Clonsura and adjacent areas. We are dedicated to the restoration and rejuvenation of peat milled bogs and peatlands and the protection of archaeological finds such as the Bronze Age Walkway at Mayne Bog. Our submission supports Westmeath County Councils attempts to protect our environment and heritage whilst noting issues which may prove contrary to our aims.
Please see attached written submission.
St Pauls GFC Clonmellon are a Gaelic Football Club based in Clonmellon village. We feel that sport and recreation is a central part to a healthy community. Our club have developed our facilities over the last 5 years with the help of Westmeath Community Development and Westmeath County Council. We are committed to continue to develop our facilities for the benefit of our village for the generations to come. Development of facilities like ours should be a central part of Westmeath County Development plan 2021-2027. Our club grounds are centrally located in our village, we feel that the development of our facilities can offer a safe enviroment for all ages to both meet members of their community, exercise and enjoys the positives that our village has to offer.
We would like to develop a floodlit walking track and improve our facilities in the next couple of years and would like to see community projects like this central to the development plan.
LOUGHNAVALLEY
Submission Re: ZONING Loughnavalley and Water Treatment Plant
Dear Sir/Madam,
Please find attached Sitemap showing my landholding at Loughnvalley.
I understand the Loughnavalley Community has submitted that Loughnavalley obtain enhanced planning status in connection with its role as the gateway to Uisneach and as the future provider of various tourism-related services to Uisneach.
In this regard, I am amenable to the provision of lands for the purposes of installation of a community sewerage treatment plant to service future tourism development with my land being ideally located due to the presence of a substantial watercourse on the lands.
In addition, I wish to submit that some of my lands be considered to be brought within the area permitted to be zoned for low density residential development as set out on the attached map.
Sitemap shows:
Yours etc.,
Owen Cuskelly
Please see attached
Submission by Elgin Energy to the Consultation on Westmeath County Council Development Plan 2021-2027
Introduction
This submission is made by Elgin Energy in response to the consultation on Westmeath’s Development Plan 2021 – 2027.
Elgin Energy is an international solar developer with operations in Ireland, UK and Australia. To date, we have delivered 21 projects / 230MW including the largest solar farms in Scotland (Errol, 13MW) and Northern Ireland (Bann Road, 46MW). Elgin Energy has secured planning permission for twenty-three solar farms across Ireland, two of which are in County Westmeath. We are continuing to develop solar in the County with the aim of delivering clean, renewable energy to 15,000 local homes. With the right policy objectives in place, these projects can provide a significant contribution to Westmeath’s renewable energy targets.
We commend Westmeath County Council for calling on public submissions as part of the consultation on the new Development Plan. All development plans must be considered in line with national targets and guidelines. As set out in the Climate Action Plan 2019 and as referenced in your consultation document, the Government has set a target of 70% renewable penetration coupled with replacing coal and peat-fired plants by 2030. Under the National Planning Framework, in its support for roll-out of renewables and protection and enhancement of carbon pools, the Government stresses the necessity to ensure “that climate change continues to be taken into account as a matter of course in planning-related decision-making processes.” In order to achieve 2030 targets a unified national approach supporting the installation of renewable projects expeditiously is imperative.
This submission focuses on the following areas: electric vehicles, renewable energy sources, solar energy, climate and development contributions. We have provided information below relevant to our expertise and experience.
10.4.9 Electric Vehicles
Elgin Energy believes for the successful implementation of EV’s on Irish roads there needs to be an increase in charging infrastructure available throughout the country. This coupled with an increase in green energy to provide power to that infrastructure, can lead to a decrease in fossil fuel consumption in the transport sector and a better quality of air due to decreased particulates. We are supportive of Westmeath’s Transport and Infrastructure Policy objectives – Electric Vehicles which create the possibility to achieve this with CPO 10.39
“Facilitate the provision of electricity charging infrastructure for electric vehicles both on street and in new developments in accordance with car parking standards prescribed in Development Management Standards Chapter 16 of this plan”
CPO10.40
“Support the growth of Electric Vehicles with support facilities, through a roll-out of additional electric charging points in collaboration with relevant agencies at appropriate locations”
And CPO 10.41
“Support the prioritisation of parking for Electric Vehicles in town centre locations.”
10.22 Renewable Energy Sources
Elgin Energy would like to see solar PV in all its forms being supported and pursued by Westmeath County Council. The development of these projects (particularly ground mounted solar farms) is reliant on their proximity to the existing grid network.
Energy storage technologies should also be pursued to support the further development of renewable projects.
Elgin Energy believe the most cost effective, time effective and non-intrusive way to meet our climate goals is with the deployment of solar energy. This directly correlates with the Westmeath development plan energy policy objective CPO 10.128
“Support local, regional, national and international initiatives for limiting emissions of greenhouse gases through energy efficiency and the development of renewable energy sources which make use of the natural resources in an environmentally acceptable manner and having particular regard to the requirements of the habitats directive”
10.24 Solar Energy
Ireland has a very similar solar resource to that of the UK which has over 12 GW of installed Solar connected to the grid. The market expectations in Europe will grow from 80GW to between 300 and 500GW by 2030.
The solar resource in Ireland varies only slightly from Cork to Donegal which should not limit the potential development throughout the island of Ireland and specifically County Westmeath. Elgin has successfully deployed one of the most northerly situated projects in the world, in Perth, Scotland which is providing power into the local national grid.
Elgin Energy is continuing to develop solar projects throughout Ireland and more specifically in County Westmeath. We therefore support the inclusion of CPO 10.139
“Support Ireland’s renewable energy commitments outlined in national policy by facilitating solar power where such development does not have a negative impact on the surrounding environment, landscape, historic buildings or local amenities”
and CPO 10.140
“Encourage and support the development of solar energy infrastructure, including solar PV, solar thermal and seasonal storage facilities”
Elgin Energy have delivered 56 projects through the planning system across the UK and Ireland over the last 7 years and recognise the importance of undertaking a robust assessment of the project in advance of submission. We have reviewed CPO 10.141 and believe it addresses the key considerations, namely;
“Ensure that proposals for solar farms consider the following criteria:
The Landscape Character of the County.
Visual impact particularly on raised/elevated sites.
Zone of visual influence and visual impact of the structures.
Glint and glare report and potential impact on adjoining road networks and dwellings.
Road access and impact on road network serving the site during the construction phase (A pre and post construction impact report may be required).
Archaeological Impact.
Incorporation of security measures – use of CCTV/surveillance cameras and security fencing.
The suitability/strength of the grid and accessibility to it.
The suitability of the site, having regard to other land use policies, including the need to protect areas of important built and natural heritage.
Decommissioning of obsolete infrastructure and after-use.”
We believe the combination of the aforementioned policies should support the decarbonisation of Westmeath through the delivery of solar projects while mitigating any potential negative impacts on the surrounding environments.
Climate Action
11.1 Aim
“To transition to a low carbon and climate resilient County, with an emphasis on reduction in energy demand and greenhouse gas emissions, through a combination of effective mitigation and adaptation responses to climate change”
Solar PV is the fastest deployable renewable energy in the world therefore it is best placed to assist Westmeath County Council with decarbonisation of its electricity network. Solar PV is low impact and can be located close to demand centres and make use of existing electrical infrastructure. At the end of the project’s life, the project is decommissioned and the infrastructure removed and recycled. The land can then be restored to its original use.
By nurturing the development of renewable projects, Westmeath County Council can generate additional investment opportunities by attracting businesses that want their operations to be powered by renewable energy, such as data centres.
Producing indigenous renewable energy reduces our dependence on imported energy and increases our security of supply. Irish renewable energy generation in 2017 avoided €278 million in fossil fuel imports, reducing import dependency from 88% in 2015 to 66% in 2017.
The solar industry is set to continue its rate of progress as the cost of solar panels continues to decline, and the technology becomes cost-competitive with conventional generation such as coal and oil. With support from Government and local Councils, Ireland can begin to capitalise on the opportunity provided by solar PV and introduce competitive clean energy to our national grid. The UK has already installed 12,000MW of solar PV. With appropriate policies in place Ireland can meet a similar target.
County Westmeath consists of approximately 184,000 hectares of land. Of that, 330 hectares have been assigned for solar energy to date which equates to 0.0018% of the total area. Clearly a significant increase in the land used for solar panels will not have a material impact on the land available in the County, but it will have a material impact on the amount of renewable energy that can be generated within the County and accelerate the transition to a low carbon economy and a climate resistant County.
Development Contribution Scheme
Elgin Energy is committed to working with all county councils throughout Ireland and have worked very closely with the appropriate planning authorities in the UK to support local projects in the vicinity of our solar farms. We wish to do the same in Westmeath and throughout Ireland in the coming years, however with the current development contribution scheme set at such a high rate, the ability to provide local support is limited.
A typical 1MW solar project will produce 900k kwh per annum (powering roughly 250 houses). In comparison to this, a 1MW wind farm will produce approx. 2,700 kwh per annum (powering roughly 650 houses). The output (and therefore revenue) from a solar farm is approx. 1/3 of that of a wind farm however the development contribution scheme typically applies the same contribution to both wind and solar. We would respectfully suggest that the Development Contribution Scheme is amended to reflect this disparity and that the contribution for solar is reduced accordingly.
Conclusion
As outlined above, Elgin Energy believes that solar PV can form an essential part of the County Council Development Plan 2021-2027 and solar farms can provide several benefits to local communities and the wider Westmeath County. They can assist Westmeath County Council in boosting local economies, potentially attract new business, provide beneficial community funding, produce clean renewable energy and make a significant contribution towards local and national climate change targets.
Elgin Energy is happy to provide our insight and experience to assist Westmeath County Council in further developing the County Development Plan 2021 – 2027 particularly for Climate Action & Energy objectives. We look forward to continued engagement with Westmeath County Council on this matter.
If you would like further information on any details in this document or solar PV in general, please contact anne.arnold@elgin-energy.com. To learn more about Elgin Energy and the work we do, please visit our website www.elgin-energy.com.
Please see the attached document for An Taisce's submission.
Please note that this submission applies to the entirety of the Draft Westmeath County Development Plan.
Please see attached Statkraft Ireland's submission in relation to wind enrgy development as out lined in the draft CDP.
There are two points I would like you to consider
To meet these needs, Athlone needs to be able to offer housing on the higher end of the market in the villages within a short commute. I believe more land should be zoned residential in some of the smaller villages outside Athlone. In particular, I would support any proposal to increase the amount of land being zoned around Glasson village.
Glasson is a well serviced village, with shop (mini-supermarket), pubs and restaurants all in the village, golf course, pitches and lake right on the doorstep. It is a very short commute to Athlone and I believe offers all that is needed in terms of being an appropriate residential location for foreign direct investment companies as well as for senior people that established companies are attempting to attract to the area. The only obstacle is that currently, the plan is to extend the village by a tiny amount and really doesn’t give the village the opportunity to support the economic growth of the county. I fully support any decision to expand the amount of zoned land in the village, particularly on that Athlone side with footpath access to the centre of the village.
I suggest that Policy CPO 12.37 be strengthened by referring to tree protection standards follows BSI e.g BS 5837:2012 and BS: 3998:2010 among others.
Suggested rewording:
Discourage the felling of mature trees and hedgerow, particularly species rich roadside and townland boundary hedgerows to facilitate development and seek Tree Management Plans to ensure that trees are strongly protected during development according to BS standards, and ensure trees are incorporated into the design of new developments
The following Policy CPO 12.38 regarding the protection of hedgerows should be strenghtened to include the methodology around hedgerow conservation and removal. This methodology should be set out as part of the conditions of development and heritage officers should be notified of the planned removal of any hedgerows in applications.
Suggested rewording
Protect and preserve existing hedgerows in new developments, particularly species rich roadside and townland boundary hedgerows, and where their removal is necessary during the course of road works or other works ensure the highest-standard methodology is used for their assessment, removal and protection of the hedgerow network, and seek their replacement with new hedgerows of native species indigenous to the area.
We wish to rezone land currently proposed as sporting/recreational to residential development land.
To rezone land currently proposed as sporting/recreational to residential development land.
To facilitate the demand for low density high class sustainable housing especially in light of the changing home requirements post COVID 19 Lockdown